Download your free guide to every item under Russian trade sanctions

What is the Common High Priority List?

The Common High Priority List has been developed by the UK, US, EU and Japan which includes many items found on the battlefield in Ukraine. All these items are under sanction. The list is divided into four Tiers, each containing particularly sensitive items such as integrated circuits used in Russian weapons systems, as well as mundane items like ball bearings and TV cameras.

There are dozens and dozens of individual items listed on the Common High Priority List. These items should be treated like handling stolen goods. Transporting, selling, buying, shipping or otherwise being connected to the supply of these goods to sanctioned entities is a criminal offence.

There are a number of red flags to be aware of when dealing with sanctioned items, and where there is a risk of a sanctions breach. A single red flag is not necessarily indicative of illicit or suspicious activity. The surrounding facts and circumstances should be considered before determining next steps, like submitting a suspicious activity report.

Breaching trade sanctions is a strict liability offence, meaning even an innocent mistake could lead to criminal prosecution. The UK government is setting up a new regulator to deal specifically with trade sanctions. Similar to the operation of the OFSI, the new Office of Trade Sanctions Implementation will have investigatory powers, will be able to issue civil penalties for strict liability breaches, and refer cases for criminal prosecution.

No matter what industry you are in, violating trade sanctions can lead to warnings, fines, and criminal prosection. Download your free guide to the Common High Priority List, and ensure that your business is not at risk of violating Russian trade sanctions.