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.


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
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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