Did you know that the Bureau of Industry and Security has issued a suggested End User/End Use Certification template and due diligence guidance that can be used to mitigate against unauthorized diversion of electronic parts and components to Russia, Belarus and the occupied territories of Ukraine? The specific guidance and recommended EUC template can be found HERE. The Russian war machine is starved for western electronic parts and components and Russia is using any and all means to evade western export controls. BIS is suggesting use of a tightly worded EUC document combined with requiring customers to provide copies of business licenses (translated into English) prior to exporting select sensitive items, that are normally No License Required (NLR) and found in Category 85 of the Harmonized Tariff Schedule (HTS). In consideration of today’s heightened geopolitical environment, it is more important than ever to Know Your Customer prior to exporting. At TSI Global Consulting we are expanding the scope beyond category 85 and are now advising exporters of most EAR99 items in a wide range of HTS categories to, in many cases, especially when exporting to countries that are not members of the Global Export Controls Coalition (GACC), use this BIS recommended EUC certification when vetting export transactions with new customers. For specific transaction related advice and guidance call TSI Global Consulting (210) 757-0618 and we will assess your unique situation and devise strategies, and guidance to protect your company from possible EAR violations through mitigating unauthorized diversion to Russia.

Image by Vlad Aivazovsky from Pixabay

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