On July 10, BIS released new guidance strongly encouraging companies involved in exporting, reexporting, or transferring (in-country) Common High Priority List (CHPL) items to screen transaction parties against the list maintained by the Trade Integrity Project (TIP) (in addition to the Consolidated Screening List).
TIP is an initiative of the UK-based Open-Source Centre that monitors military and dual-use trade with Russia. The TIP website displays entities that have shipped CHPL items to Russia since 2023, according to publicly available trade data.
The guidance also outlines the different actions that BIS takes to inform industry and academia about parties—beyond those identified on public screening lists like the Entity List—that present diversion risks.
This article is presented for informational purposes only and is not intended to constitute legal advice.