Earlier this week, the U.S. Bureau of Industry and Security (BIS) published new guidance on identifying and responding to parties that present a risk of diversion of export-controlled items to countries or entities of concern. Within that guidance was a new recommended best practice to screen transaction parties using a new online resource from the Trade Integrity Project (TIP). TIP provides a searchable tool that identifies third-country suppliers that have exported items on the Common High Priority List (CHPL) to Russia. CHPL items are those that items pose a heightened risk of being diverted illegally to Russia due to their importance to Russia’s defense industry and war effort.

According to the TIP website, the search tool is currently limited to trade data from 2023 and items in Tier 1 and 4.b of the CHPL. Tier 1 targets Harmonized System Code 8542, which covers electronic integrated circuits and related components. Items classified under 8542 range from advanced processors to commodity-level chips used in everyday consumer goods. Tier 4.b targets computer numerically controlled (CNC) machine tools and components.

The TIP website is an initiative of the UK-based Open-Source Center. UK business records indicate that Open-Source Centre Limited is associated with James Byrne, the former director of open-source intelligence and analysis at the Royal United Services Institute (RUSI)—a UK defense thinktank.

BIS publicizing TIP and recommending the tool’s use by the trade community to screen transaction parties indicates the seriousness with which the agency is addressing evasion of U.S. and allied export controls. Since the Russian invasion of Ukraine, BIS has been encouraging exporters and other parties involved in export transactions to watch out for the diversion of low-tech items found useful by Russia on the battlefield. Previous outreach by BIS has included asking banks to verify the export control status of processed transactions and sending letters to U.S. companies that list foreign suppliers purchasing CHPL items for shipment to Russia.

The reputational risk of unwittingly appearing in a database such as TIP is well worth taking the time to conduct a thorough screening of potential customers to manufacturers and exporters of CHPL items.

Our prior publications on Russia sanctions and export control risks are available here and here.