G7 Issues Joint Guidance On Evasion Of Sanctions And Export Controls On Russia

On September 24, 2024, for the first time, the United States, Canada, France, Germany, Italy, Japan, the United Kingdom, and the European Union (collectively, the G7) published joint guidance for industry on preventing the evasion of export controls and sanctions imposed on Russia. The joint guidance outlines (i) Russian efforts to obtain Common High Priority List (CHPL) items; (ii) red flag indicators of possible export control and/or sanctions evasion; and (iii) best practices for industry to use to try to address red flags through additional due diligence and compliance measures. The guidance reflects the G7's continued emphasis on preventing diversion of CHPL items to Russia. Accordingly, parties involved in the export, reexport, or transfer (in-country) of CHPL items should be aware that these items are an enforcement priority in these jurisdictions.