OFAC SANCTIONS ADVISORY - June 12, 2024
2 Since Russia’s further invasion of Ukraine, the United States and partners have identied key items that Russia is seeking to procure for its
weapons programs. Such key items include all of the specied items described in this advisory, as well as the Common High Priority Items
List, which describes a subset of items that are restricted from trade to Russia by the United States and its allies. The Common High Priority
List is intended for exporters, reexporters, and customs oicials, and identies broad categories of items by Harmonized System (HS) Codes,
which are the foundation of the import and export classication systems used in the United States and by many trading partners. In contrast,
the list of specied items described in this advisory is intended for use by nancial institutions in implementing controls to mitigate
sanctions risks under OFAC’s authorities.
3 The listed measures are illustrative only and do not account for obligations that a nancial institution may have related to historical
activities, such as ling reports of suspicious transactions in the applicable jurisdiction(s).
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Identifying and Mitigating Sanctions Risks
To mitigate sanctions risk, foreign nancial institutions should take steps to identify and minimize their
exposure to activity involving Russia’s military-industrial base and those that support it. These steps are
in addition to baseline customer due diligence (CDD) procedures and other anti-money laundering (AML)
controls, which can be critical for detecting, stopping, and reporting attempted or suspected sanctions
evasion. OFAC recognizes that there is not a “one-size-ts-all” approach to identifying and mitigating
exposure to activity involving Russia’s military-industrial base, and thus foreign nancial institutions may
take various approaches to identifying and mitigating their relative sanctions risk. Each institution should
implement controls commensurate with its risk prole and current exposure to Russia’s military-industrial
base and its supporters.
For example, small- and medium-size nancial institutions located in jurisdictions that continue to engage
in signicant trade with Russia may present a particularly high risk of providing services involving Russia’s
military-industrial base. OFAC recommends that such nancial institutions carefully review the examples
of controls identied below to assess whether implementing one or more of these controls may assist in
identifying and mitigating this risk.
Examples of controls to mitigate sanctions risk may include:
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► Screening transactions, customers, counterparties, and associated parties against relevant
sanctions lists, such as OFAC’s Specially Designated Nationals and Blocked Persons List
(SDN List), to prevent the provision of any service to persons blocked pursuant to E.O.
The list of specied items can be found here. Treasury has identied the specied items because they
are critical for Russia’s war eort, including for the production of advanced precision-guided weapons
and other critical items, and Russia is actively working to import them from third countries to fuel its
war machine. Foreign nancial institutions should use this list of specied items for the purpose
of mitigating sanctions risk under Treasury’s sanctions authorities described in this advisory.
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If in the course of its due diligence, a foreign nancial institution is unsure whether a particular item
is the same as one identied on the list of specied items (or could otherwise potentially be linked
to Russia’s military-industrial base), the institution should conduct further due diligence regarding
the particular customer and/or transaction and take appropriate mitigation measures, as described
further below.