Trade Matters

1. Action Required: BIS Unveils New Guidelines to Combat Export Diversion Risks

The Bureau of Industry and Security (BIS) issued new guidance to prevent the diversion of controlled items to Russia. This guidance recommends the use of the Trade Integrity Project (TIP) database, which tracks suppliers with histories of exporting sensitive items to Russia. Businesses are advised to screen transactions against the TIP list, conduct thorough due diligence, and maintain detailed compliance records. Check and see whether this new list is already incorporated into your existing diligence software. Companies will receive "red flag" letters if their customers are suspected of violating export controls and "is informed" letters for additional licensing requirements on specific transactions. Failure to comply with these requirements can result in administrative or criminal penalties.