On September 24, 2024, the Group of 7 Countries (the United States, Canada, France, Germany, Italy, Japan, the United Kingdom, and the European Union) published joint guidance for industry on prevention of evasion of the export controls and sanctions imposed on Russia since its war on Ukraine in February 2022. Since February 2022, the G7 and other members of the Global Export Control Coalition (GECC) have implemented unprecedented multilateral sanctions and export controls that restrict Russia's access to technologies and other sensitive articles it needs to further its illegal war in Ukraine. Last year, the G7 created a sub-working group on export control enforcement to support the exchange of information, including through the issuance of coordinated guidance.

The guidance highlights preventing the diversion of controlled items to Russia, including through third countries, and provides best practices in identifying Russian sanctions evasion tactics. The guidance document includes: (1) a list of items which pose a heightened risk of being diverted to Russia (i.e. integrated circuits); (2) updated red flag indicators of potential export control and/or sanctions evasion; (3) best practices for industry to address these red flags; and (4) screening tools and resources to assist with due diligence. Click here to view the full guidance document: https://www.bis.gov/press-release/g7-announces-industry-guidance-preventing-evasion-export-controls-and-sanctions. 

As Russian sanctions evasion tactics continue to evolve, this guidance aims to assist industry in complying with multilateral export controls and sanctions, mitigating risk and exposure to liability, and preventing reputational harm.