Commerce, International Partners Continue Coordination in Response to Russia’s Illegal Invasion of Ukraine

U.S., U.K, EU, and Japan meet in Washington, D.C., release updated list of priority items

Washington, D.C. – The Department of Commerce’s Bureau of Industry and Security (BIS) today announces important updates to its list of controlled “common high priority” items identified as critical to Russia’s war effort following productive meetings with key members of the Global Export Control Coalition.

Since the onset of Russia’s further invasion of Ukraine in February 2022, the United States and its international allies and partners have implemented a series of export controls that restrict Russia’s access to the items it needs to sustain the war. While BIS’s controls cover a vast array of items necessary to fuel Russia’s war machine, certain items are more significant to Russian weaponry than others. As part of this effort and in coordination with our partners in the United Kingdom, the European Union and Japan, in July 2023 BIS published a list of 38 high priority items that Russia seeks to procure for its weapons programs. The list is divided into four tiers, ranked according to their relative degree of criticality.

In close coordination with our partners, BIS has added seven new Harmonized System (HS) codes to the list, including bearings needed for heavy vehicles or other machinery and antennae used for navigation systems. Additionally, Tier 3 has been divided into mechanical and nonmechanical items to provide greater clarity.

As published in our previous guidance involving the nine HS codes in Tiers 1 and 2 of highest priority, exporters and reexporters are strongly encouraged to conduct due diligence when encountering the listed HS codes to identify possible third-party intermediaries and attempts at evasion of U.S. export controls.

Additional Background on Commerce’s Response to Russia’s Invasion of Ukraine:

Since the start of Russia’s illegal further invasion of Ukraine in February 2022, BIS has taken more than 50 regulatory and enforcement actions in concert with international and interagency allies and partners to restrict Russia’s access to items it needs to sustain its war effort and to enforce those restrictions. As a result of these restrictions, total Global Export Control Coalition exports to Russia have decreased by 52.3 percent ($81.1 billion) which has led to numerous challenges for the Russian defense industrial base including the bankruptcy of Russia’s most advanced semiconductor producer, ongoing struggles with supplies to repair, replace, and replenish a variety of military equipment, and efforts to acquire weapons and other support from pariah states like Iran and North Korea. Commerce has also worked in concert with interagency partners like DOD, DOJ, Treasury, and others to address Iran’s provision of drones to Russia, identify and break up illicit procurement networks, and continue to refine and coordinate controls on items with our international partners. BIS has also added over 500 entities to the Entity List in connection with Russia’s invasion of Ukraine and continued military aggression, as substantially enabled by Belarus, including over 60 in more than 20 countries other than Russia and Belarus. In addition to our GECC partners, we will continue to coordinate with non-GECC countries about our controls, and will continue to monitor developments and act as appropriate to deny Russia the items it needs to sustain its war machine. Additional information on Russian evasion tactics including common evasion red flags, compliance guidance for industry and other stakeholders, and other resources are available online at: https://www.bis.doc.gov/index.php/2011-09-14-14-10-06/russia-export-con….

Additional information on BIS’s actions in response to Russia’s invasion of Ukraine is available here: https://www.bis.doc.gov/index.php/policy-guidance/country-guidance/russia-belarus.