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United States, Close Allies Publish Guidance to Counter Russian Sanctions Evasion

The export enforcement five soldiers

The Export Enforcement Five, or E5, partnership that groups the governments of the United States, United Kingdom, Canada, Australia and New Zealand has issued new guidance to counter Russia’s evasion of sanctions through the use of third countries.

The document, available for download from the U.S. Bureau of Industry and Security website, identifies 45 prioritized Harmonized System codes corresponding to materials that Russia needs to build weapons against Ukraine.

HS is a product nomenclature developed by the World Customs Organization and used around the world as the basis for custom tariffs. 

The guidance also describes patterns and red flag indicators associated with importers from countries outside of the Global Export Control Coalition. Organizations may use the information to determine if an entity or activity is part of sanctions evasion.

“Responding effectively to Russia’s aggression against Ukraine is a global effort, and today’s joint guidance is another demonstration of the resolve with which [the] U.S. and our partners and allies are disrupting Russia’s efforts to circumvent export controls,” Alan Estevez, undersecretary for industry and security at the U.S. Department of Commerce, said Tuesday.

Established in June, E5 aims to ensure that each member state’s export controls against Russia are enforced and effective. Under the grouping, the five nations committed to conduct joint investigations and coordinate enforcement actions against entities that do not comply with sanctions. The U.S. and its allies also agreed to strengthen collaboration with industry to curb Russia’s efforts to divert high-priority items through third countries.

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