As a follow-up to the establishment of the “Export Enforcement Five” or “E5” partnership to coordinate on export control enforcement issues in June 2023, the governments of Australia, Canada, New Zealand, the United Kingdom, and the United States have issued joint guidance to industry and academia identifying high priority items critical to Russian weapons systems and urging specific actions to prevent diversion of these items to Russia through third countries.
The quint-seal guidance provides industry and academia with the list of 45 prioritized Harmonized System (HS) codes containing items Russia needs for its weapons systems, of which nine (9) codes are the highest priority. The guidance then identifies anomalous patterns associated with importers in countries outside of the Global Export Control Coalition (GECC), which is the 39-member global coalition that has implemented substantially similar controls in response to Russia’s invasion of Ukraine, that may raise diversion concerns, due diligence tips for screening such parties, and red flag indicators that may be relevant to exporters to assist in determining whether an activity may be connected to export control and/or sanctions evasion.
The full guidance is available online here: https://www.bis.doc.gov/index.php/documents/aboutbis/ newsroom/press-releases/3336-2023-09-26-export-enforcement-five-guidance-for-industryand- academia-priority-hs-codes/file.
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