Western Tech Fuelling Russia's War – The WMD dual-use technologies list every business must heed!

In a stark reminder of the ongoing geopolitical tensions, international powers are tightening the noose on Russia's military supply chains through the

• Common High Priority List (CHPL).

The Common High Priority List (CHPL)

• Originated IN 2022 as a collaborative effort among the United States (led by the Bureau of Industry and Security, or BIS), the European Union (EU), Japan, and the United Kingdom (UK) to identify and restrict dual-use items critical to Russia's military capabilities amid its invasion of Ukraine.
• It focuses on goods recovered from Ukrainian battlefields or essential for Russian weapons production, such as electronics, components, and manufacturing equipment.
• The list is not a ban itself but a tool to heighten due diligence, flag diversion risks, and support enforcement of export controls and sanctions..
• Has  50 HS codes, with no major updates since February 2024. [Below there are examples of the EU's list of 50 HS codes - The list totals 50 HS codes across the four tiers (with Tier 3 and Tier 4 split into sub-tiers).
• HS Code, short for Harmonised System Code, is a standardised numerical system used globally to classify traded products for international commerce.
• Developed and maintained by the World Customs Organisation (WCO), it serves as a universal language for identifying goods, ensuring consistency in tariffs, trade statistics, and regulatory compliance across more than 200 countries and territories.
• The system covers over 5,000 commodity groups, making it essential for customs authorities, exporters, importers, and governments to track and control the movement of goods.
• HS codes are crucial for identifying restricted items (e.g., 8542.31 for processors and controllers in integrated circuits).
• They help enforce export controls by pinpointing dual-use technologies that could be diverted to military applications.
• Enforcement continues through G7/GECC coordination, focusing on third-country diversion (e.g., China, Turkey, India).
• Analyses show partial success: Exports of Tier 1-2 items to Russia dropped significantly, but lower-tier items persist via intermediaries.
• List evolves based on battlefield intelligence and evasion patterns, supporting broader goals to degrade Russia's war economy.
• For the latest, check official sources like BIS or the EU's CHPL document.

COMMON HIGH PRIORITY LIST (CHPL).

• The CHPL
• Is a collaborative sanctions tool, forged by the UK, US, EU, and Japan, that targets everyday electronics and components recovered from Ukrainian battlefields

• Primarily focusing on electronics, components, and manufacturing equipment,
• Aims to deprive Moscow of the capacity to sustain its invasion of Ukraine by curbing the diversion of dual-use technologies.
• Structured into tiers for targeted scrutiny, the CHPL categorises items by their military criticality:
• Tier 1: Integrated circuits like processors and memories (HS 8542 codes), the "brains" behind computing and control in advanced weapons.
• Tier 2: Electronic components such as communications machines (HS 8517), vital for data transmission.
• Tier 3A: Additional electronics, including converters, cameras, and antennas.
• Tier 3B: Mechanical parts like bearings and aircraft components.
• Tier 4A: Manufacturing and testing equipment for circuits.
• Tier 4B: CNC machine tools for precision metalworking.
• G7 recommendations urge businesses to screen transactions, verify end users, and report suspicious activity to prevent breaches that could erode global security.

CHPL SANCTION RISK

• Sanctions evasion remains rampant, with third countries like China, India, and Turkey implicated in smuggling millions of CHPL goods to Russia.
• 2022 = Red flags include new shell companies formed after 2022, overpayments, mismatched details, or links to military sites.
• 2024 = Treasury sanctions on 275 actors in October 2024,
• 2025 = Recent actions, such as the U.S. Entity List additions in September 2025 targeting diverters of CHPL items,  
• In an era where tech knows no borders, the CHPL serves as a wake-up call:
• Your supply chain could be the next link in Russia's arsenal.
• Stay vigilant, peace depends on it.

WHAT TO DO AND WHY

• Screen Transactions: Flag CHPL HS codes, verify end-users/end-uses, and conduct enhanced due diligence for high-risk countries/industries. Why? To prevent unwitting involvement in sanctions violations.
• Monitor Red Flags: Escalate suspicions (e.g., via SARs) and train teams. Why? Early detection mitigates legal and financial risks.
• Implement Controls: Update policies, use compliance tools (e.g., from), and audit supply chains. Why? Ensures organisational resilience, aligns with international efforts to isolate Russia's military, and protects against penalties.
• Report and Collaborate: Share intelligence internally and with regulators. Why? Collective action strengthens enforcement and global stability.

WHY MONITOR?

• A single breach can expose organisations to enforcement actions by bodies such as the US BIS, the UK NCA, or EU authorities, eroding trust and business viability.

KEY RISKS AND RED FLAGS

Sanctions evasion often involves third countries or shell companies. Watch for:

• New entities (post-February 2022) in diversion hotspots.
• Lack of transparency on end-users or overpayments.
• Mismatched details (e.g., phone codes, business fit) or military links.
• Atypical routing or minimal online presence.

PRODUCTION COUNTRIES AND INDUSTRIES

• These items, often produced in powerhouses such as the US, China, Europe [Germany], Taiwan, Japan, AND South Korea, span industries from electronics manufacturing to telecommunications and R&D, highlighting their dual-use risk.
• With a focus on semiconductors and precision engineering; industries at risk include electronics manufacturing, telecommunications, automotive, IT, R&D, and semiconductor production.
• The dual-use nature heightens the need for vigilance across global supply chains.
• foreignpolicy.com = Russia-Ukraine War: How Western Electronics Help Violate Sanctions

KEY RED FLAGS FOR SANCTIONS RISKS

Be vigilant for these indicators when reviewing transactions involving CHPL items. A single flag isn't conclusive, but multiple or contextual factors warrant escalation (e.g., SAR to JFIU – NCA - FIU). Here's the list:

1. Transactions for CHPL goods from companies incorporated after February 24, 2022, in known diversion destinations.
2. Customers refusing to provide details on banks, shippers, third parties, end-users, end-use, or ownership.
3. Smaller payments from the same end-user's foreign account to multiple similar CHPL suppliers.
4. Significant overpayment for CHPL items compared to market prices.
5. Purchases under letters of credit consigned to the issuing bank, not the end-user, with documents omitting the actual end-user.
6. Entities with minimal web presence (e.g., no website or non-domain email).
7. Phone numbers with country codes mismatched to the destination.
8. Items not fitting the purchaser's line of business.
9. Customer name/address similar to the UK sanctions list entities.
10. Purported civil end-users with military connections (e.g., addresses near military facilities).
11. Companies co-located or sharing ownership with sanctioned entities.
12. Use of open accounts/lines of credit in diversionary destinations.
13. Last-minute payment routing changes from/to countries of concern.
14. Payments from transhipment points or atypical shipping routes.

If you spot these, please document and report them immediately using our internal escalation protocol.

Key Countries Involved in Production

These nations are major producers of CHPL goods, and there is heightened scrutiny for exports from/re-exports to Russia:

• United States (electronic test equipment, semiconductors)
• China (electronic test equipment, semiconductors)
• Germany (precision engineering, semiconductor testing)
• Taiwan (high-quality PCB production)
• Japan (advanced electronic testing, precision engineering)
• South Korea (semiconductor manufacturing)
• Europe (general communications and electronics)

KEY INDUSTRIES INVOLVED IN USE

CHPL items are used across sectors with potential dual-use risks:

• Electronics Manufacturing
• Consumer Electronics
• Telecommunications
• Material Handling
• Automotive Electronics
• Energy and Power
• Research and Development (R&D)
• Integrated Circuit Production
• Healthcare
• Failure Analysis Services
• Information Technology (IT)
• Semiconductor Manufacturing

EU'S LIST OF 50 HS CODES –

• The list totals 50 HS codes across the four tiers (with Tier 3 and Tier 4 split into sub-tiers)

OVERVIEW OF TIERS WITH EXAMPLES

Here's a breakdown of each tier, including sample items, uses, industries, and production countries

Tier 1: Integrated Circuits

Focus: Processors, controllers, memories, amplifiers, and other circuits fundamental to computing and control systems. Examples:

• 8542.31: Processors and controllers (used for computing, control systems, signal processing).
• 8542.32: Memories (data storage).
• 8542.33: Amplifiers (signal enhancement).
• 8542.39: Other integrated circuits. Industries: IT, Telecommunications, Consumer Electronics, Automotive, Industrial Automation. Production Countries: US, China, South Korea, Taiwan.

Tier 2: Electronic Components

Focus: Communications machines and related parts. Examples:

• 8517.62: Machines for voice/image/data transmission (used in networks, broadcasting, data centres).
• 8526.91: Radio navigational aid apparatus.
• 8532.21: Tantalum capacitors.
• 8532.24: Multilayer ceramic capacitors.
• 8548.00: Electrical parts not elsewhere specified. Industries: Telecommunications, Broadcasting, IT, Internet Services. Production Countries: US, China, Europe, Japan.

Tier 3A: Electronic Components Used in Russian Weapons Systems

Focus: Transformers, converters, communications equipment, cameras, antennas, connectors, diodes, transistors. Examples:

• 8504.40: Static converters (power modification in electronics, energy).
• 8517.69: Other transmission/reception apparatus (wired/wireless networks).
• 8525.89: Digital/TV cameras (broadcasting, photography).
• 8529.10: Antennas and reflectors.
• 8536.69: Coaxial connectors (telecom, broadcasting).
• 8541.10: Diodes. Industries: Electronics/IT, Energy, Manufacturing, Telecommunications, Media/Entertainment, Aerospace/Defence. Production Countries: US, China, Germany, Japan, South Korea, and Europe.

Tier 3B: Mechanical and Other Components Used in Russian Weapons Systems

Focus: Bearings, aircraft parts, lasers, navigational instruments. Examples:

• 8482.10: Ball bearings (automotive, machinery).
• 8482.20: Tapered roller bearings (heavy machinery, railways).
• 8482.30: Spherical roller bearings (mining, paper mills).
• 8482.50: Cylindrical roller bearings (machine tools, gearboxes).
• 8807.30: Aircraft parts (airframes, engines).
• 9013.10: Telescopic sights for arms.
• 9014.20: Aeronautical navigation instruments. Industries: Automotive, Manufacturing, Aerospace/Defence, Mining, Rail Transportation, Aviation. Production Countries: US, China, Germany, Japan, Europe, and Russia.

Tier 4A: Manufacturing, Production, and Quality Testing Equipment

Focus: Computers, CNC tools, semiconductor manufacturing machines. Examples:

• 8471.50: Processing units (data processing).
• 8486.10: Boule/wafer manufacturing machines (semiconductor production).
• 8486.20: Semiconductor device manufacturing.
• 8486.40: Assembly/handling equipment.
• 8534.00: Printed circuits.
• 8543.20: Signal generators.
• 9027.50: Optical radiation instruments. Industries: IT, Semiconductor Manufacturing, Electronics, Advanced Manufacturing, Aerospace/Defence. Production Countries: US, China, Taiwan, Japan, Germany, South Korea.

Tier 4B: CNC Machine Tools

Focus: Precision metalworking tools and accessories. Examples:

• 8457.10: Machining centres.
• 8458.11: Horizontal CNC lathes.
• 8458.91: Other CNC lathes.
• 8459.61: CNC milling machines.
• 8466.93: Parts and accessories. Industries: Advanced Manufacturing, Aerospace/Defence, Automotive, Electronics Production. Production Countries: US, China, Taiwan, Japan, Germany, South Korea.

Actionable Guidance

• Screening: Update your checklists to flag CHPL HS codes in trade documents. Use automated tools where possible.
• Due Diligence: Verify end-users and end-uses for any transactions involving these items/countries.
• Training: Schedule a refresher session on red flags. Contact me to arrange.
• Reporting: Escalate any suspicions promptly. Remember, compliance is everyone's responsibility.

IN SUMMARY,

• The CHPL is a frontline defence against Russia's military resupply efforts. Prioritise compliance to safeguard your organisation, uphold ethical standards, and contribute to peace efforts.
• Please stay vigilant; adhering to these sanctions protects the organisation and supports global security.
• We recommend updating policies, training teams, and using tools like those from for robust due diligence.
• Questions? Reach out. MATHEW@COMSUREGROUP.COM

References

The information in this briefing is supported by official third-party sources from the entities that developed the Common High Priority List.  

1. European Commission. "List of Common High Priority Items" (February 2024). Available at: https://finance.ec.europa.eu/system/files/2023-09/list-common-high-priority-items_en.pdf This official EU document details the CHPL, including HS codes and tiers
2. U.S. Bureau of Industry and Security (BIS). "Common High Priority Items List (CHPL)". Available at: https://www.bis.gov/licensing/country-guidance/common-high-priority-items-list-chpl. Provides U.S. guidance on the CHPL, emphasising items critical to Russian weapons systems.
3. UK Government. "Russia Sanctions: Common High Priority Items List". Available at: https://www.gov.uk/government/publications/russia-sanctions-common-high-priority-items-list/russia-sanctions-common-high-priority-items-list UK-specific list and red flags for sanctions compliance.
4. Japan Ministry of Economy, Trade and Industry (METI). "Export Ban List to Russia" (July 2023). Available at: https://www.meti.go.jp/press/2023/07/20230728001/20230728001-1-2.pdf Japanese export restrictions covering CHPL items.