Today (Wednesday, July 10th) the Bureau of Industry and Security (BIS) published new Guidance for Industry related to addressing diversion risk. The new guidance provides an overview of the various tools used by BIS (other than listing parties on one of the many BIS denied/restricted parties lists–see Consolidated List Screening) to notify industry about potential parties of concern related to risk of unauthorized diversion of items subject to the EAR to Russia and other prohibited end users and/or end uses. In addition, this new guidance includes a new “best practice” screening tool published by the Trade Integrity Project that can be used by companies and universities engaged in the export, re-export, or transfer (in-country) of common high priority list (CHPL) items in order to mitigate the chances of unauthorized diversion to Russia. The new guidance also addresses “red flags” and various new forms of red flag warning letters that BIS is now using to inform industry of customers that are at high risk for diversion. For complete details download the New Guidance from BIS or contact TSI Global Consulting at 210-757-0618.
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