On September 28, 2023, the Bureau of Industry and Security (BIS) published a press release and a best practice document regarding the export of certain controlled items that have a “heightened risk” of being diverted illegally to Russia.

The best practice document prioritizes items in nine (9) Harmonized Schedule (HS) categories as “the most significant to Russian weaponry requirements” (emphasis in original) and recommends, if any such items are being shipped to a country that is not part of the Global Export Controls Coalition, that “exporters seek assurances of compliance with U.S. export controls.” The document provides guidance on the suggested format of such assurance.

The best practice guidance can be found here:

https://www.bis.doc.gov/index.php/documents/policy-guidance/3339-tent-final-best-practice-customer-certification-v4/file

The press release can be found here:

https://www.bis.doc.gov/index.php/documents/about-bis/newsroom/press-releases/3342-2023-09-25-bis-press-release-customer-certification-v3-se/file

BIS recently updated the high priority items list, released in a notice here dated September 19, 2023:

https://www.bis.doc.gov/index.php/documents/about-bis/newsroom/press-releases/3332-2023-09-14-bis-press-release-quad-meeting-hs-code-update-final/file

The original May 19, 2023 list can be found here:

https://www.bis.doc.gov/index.php/documents/enforcement/3278-bis-guidance-to-prevent-evasion-of-prioritized-harmonized-system-codes-to-russia-final/file