U.S. BIS issues guidance to help prevent high-priority items from being diverted to Russia

New best practice guidance to help prevent items that are considered most significant to Russian weaponry requirements from being diverted

U.S. BIS issues guidance to help prevent high-priority items from being diverted to Russia

The Bureau of Industry and Security (BIS) of the U.S. Department of Commerce today issued a release [PDF 132 KB] announcing new best practice guidance for industry to help prevent items that are considered the most significant to Russian weaponry requirements from being diverted for use in Russia’s war effort on Ukraine.

Specifically, BIS recommends that exporters and reexporters of these highest priority items seek written assurances of compliance from their customers to help prevent diversion.

Read the BIS guidance [PDF 174 KB], which includes a sample written certification form.


Since the beginning of Russia’s invasion of Ukraine in February 2022, the United States and its international allies and partners have implemented a series of export controls that restrict Russia’s access to items needed to sustain the war. While BIS’s controls cover a vast array of items necessary for Russia’s war on Ukraine, certain items are more significant to Russian weaponry than others.

As part of this effort and in coordination with the UK, the EU, and Japan, BIS in July 2023 published a list of high-priority items that Russia seeks to procure for its weapons programs. The list is divided into four tiers, ranked according to their relative degree of criticality.

For more information, contact a professional with KPMG’s Trade & Customs services:

Doug Zuvich
Partner and Global Practice Leader
E: dzuvich@kpmg.com

John L. McLoughlin
Principal and East Coast Leader
E: jlmcloughlin@kpmg.com

Andy Siciliano
Partner and National Practice Leader
E: asiciliano@kpmg.com

Steve Brotherton
Principal and Global Export and Sanctions Leader
E: sbrotherton@kpmg.com

Luis (Lou) Abad
Principal, Washington National Tax
E: labad@kpmg.com

Irina Vaysfeld
E: ivaysfeld@kpmg.com

Amie Ahanchian
E: aahanchian@kpmg.com

Christopher Young
E: christopheryoung@kpmg.com

Gisele Belotto
E: gbelotto@kpmg.com

George Zaharatos
E: gzaharatos@kpmg.com

Andy Doornaert
Managing Director
E: adoornaert@kpmg.com

Jessica Libby
E: jlibby@kpmg.com
John Anderson
Managing Director
E: johneanderson@kpmg.com
Jenna Leigh Glass
Managing Director
E: jennaleighglass@kpmg.com


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