U.S. list of high-priority items at risk of being diverted illegally to Russia

Update to list of items identified as critical to Russia’s war effort on Ukraine

Update to list of items identified as critical to Russia’s war effort on Ukraine

The Bureau of Industry and Security (BIS) of the U.S. Department of Commerce today issued a release [PDF 184 KB] announcing updates to its list of controlled “common high-priority” items identified as critical to Russia’s war effort on Ukraine.

The update to the list of common high-priority items (September 14, 2023) includes seven new Harmonized System (HS) codes including bearings needed for heavy vehicles or other machinery and antennae used for navigation systems. In addition, Tier 3 has been divided into mechanical and non-mechanical items for greater clarity.

Background

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 United Kingdom, the European Union, and Japan, in 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
Principal
E: ivaysfeld@kpmg.com

Amie Ahanchian
Principal
E: aahanchian@kpmg.com

Christopher Young
Principal
E: christopheryoung@kpmg.com

Gisele Belotto
Principal
E: gbelotto@kpmg.com

George Zaharatos
Principal
E: gzaharatos@kpmg.com

Andy Doornaert
Managing Director
E: adoornaert@kpmg.com

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

The KPMG name and logo are trademarks used under license by the independent member firms of the KPMG global organization. KPMG International Limited is a private English company limited by guarantee and does not provide services to clients. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 3712, 1801 K Street NW, Washington, DC 20006.