Red Flags
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Using consolidators or reshippers which are owned/directed by Russians.
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Layering procurements through third party countries to obfuscate the end user, an example of which is the use of numerous 3rd country freight forwarders and shippers on a single transaction.
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Freight forwarding firm is listed as the product’s final destination.
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Making payments from entities located in third countries not otherwise involved with the transactions.
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Removing government/military affiliation from website.
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Consolidating shipments/shippers in the United States may be more likely to provide applicable cover for the exports of luxury goods.
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Procuring items below control thresholds while claiming civil end use.
Commodities of Concern
- Aircraft Parts and Equipment
- Antennas
- Cameras
- GPS Systems
- Inertial Measurement Units
- Integrated Circuits
- Sonar Systems
- Spectrophotometers
- Test Equipment
- Thrusters
- Underwater Communications
- Vacuum Pumps
- Wafer Fabrication Equipment/Substrates
- Oil Field Equipment
Transshipment Countries of Concern
- Armenia
- Brazil
- China
- Georgia
- India
- Israel
- Kazakhstan
- Kyrgyzstan
- Mexico
- Nicaragua
- Serbia
- Singapore
- South Africa
- Taiwan
- Tajikistan
- Turkey
- United Arab Emirates
- Uzbekistan
Naming Nomenclature
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RAO (Rossiyskaya Aktsionernaya Kompaniya), which designates a Russian joint stock company
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FGUP/FSUE (Federal’noye Gosudarstvennoye Unitarnoye Predpriyatiye), which designates a Russian Federal State Unitary Enterprise
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GK (Gorsudarstvennaya Korporatsiya), which designates a Russian State Corporation
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SPRE/NIPP (Nauchno-Issledovatel’skoye Proizvodstvennoye Predpriyatiye), which designates a Russian Scientific Research Production Enterprise
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NPO/GNPO (Gosudarstvennyy Nauchno-Proizvodstvennyy Tsentr), which designates a Russian State Research and Production Center