Russia’s invasion of Ukraine in 2022 led to a surge in imports of military, dual-use, and industrial goods by Russian defense contractors, supporting the Kremlin’s military operations. In response, a coalition of nations established the Common High Priority List (CHPL) to identify and monitor goods that are at high risk of being diverted to Russia.
To prevent diversion of regulated items, the Bureau of Industry and Security (BIS) issued guidance, along with a new screening tool called the Trade Integrity Project (TIP). Companies are advised to screen companies using TIP as a best practice. The tool features a user-friendly search engine to identify companies and universities involved in exporting, re-exporting, or transferring high-priority items.
The BIS guidance highlights specific notifications and what to do if your company receives one. The below is a summary of what to expect.
| BIS notification | Action | Responsibility |
|---|---|---|
| “Supplier List” Letters | Identification of parties of diversion concern | Determine whether any red flags are present and if present, resolve before proceeding |
| Project Guardian requests | BIS notification of red flag (i.e., knowledge of high probability that a violation may occur) | Resolve red flags to proceed |
| “Red Flag” letters | BIS notification of red flag (i.e., knowledge of high probability that a violation may occur) | Resolve red flags to proceed |
| “Is Informed” letters | Individual notice of a license requirement | Submit license application as required by letter |
If you receive any of these notifications, BIS recommends reviewing the “Know Your Customer” Guidance and Red Flags. In today’s changing international trade landscape, with increased US government scrutiny of exporters, it’s essential to develop and maintain an export compliance program to protect your business.
Not sure if your shipment requires an export license from the U.S. Department of Commerce or the U.S. Department of State? Mohawk Global Trade Advisors is here to help.