The U.S. Department of Commerce’s Bureau of Industry and Security issued new guidance to combat Russian money transfer risks and
The U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) recently issued new guidance to exporters designed to further assist BIS in combating third-party transfers to Russia. Specifically, BIS’s recent guidance outlines the various mechanisms it uses—in addition to its usual public screening lists (IE, The Unverified List, Entity List, Military End-User List, and Denied Persons List) — notify companies and universities of parties that present a risk of transfer to Russia. According to BIS, it has obtained information supporting the notifications described below from a variety of sources, including information from the export community, government data, news reports, and other open-source resources. Specific mechanisms BIS uses to prevent exporters from unknowingly exporting items to relevant parties include: "Supplier List" Letter Identify parties that present diversion risks and are not on the public screening lists but have been determined by BIS to be exporting or facilitating transactions to destinations or end-users of concern. BIS may send “suppliers list” letters…
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