In its effort to prevent diversion of items to Russia, BIS has issued a guidance memo advising of “supplier list” letters, Project Guardian requests, “red flag”
letters, and “is informed” letters – to inform companies and universities about parties (beyond those identified on our screening lists) that present diversion risks. Through these notices, BIS may inform U.S. companies of restriction and licensing requirements for companies that are not otherwise listed on U.S. sanctions list.
Please review the memo here: https://www.bis.gov/sites/default/files/files/Guidance-for-Complying-with-BIS-Letters-Identifying-Transaction-Parties-of-Diversion-Risk_v8.pdf
If you receive one of these letter, you can contact our office to review the restrictions and determine if there are steps you can take to legally export to that entity or if it is necessary to cease all activity.
This Blog is made available by Wilmarth & Associates for educational purposes as well as to give you general information and a general understanding of export law and compliance, not to provide specific legal advice. This blog is not legal advice and should not be treated as such. You must not rely on this blog as an alternative to legal advice from your attorney or other professional legal services provider. The information provided on this website is presented “as is” without any representations or warranties, express or implied.
