Last updated: 9 January 2025

This Advisory is produced by the Australian Sanctions Office (ASO) within the Department of Foreign Affairs and Trade (DFAT). It provides a list of certain items (known in other jurisdictions as the 'common high priority items') that are of particular significance to Russian military capabilities. Exporters and re-exporters (such as manufacturers, distributors, and resellers) as well as their service providers (such as financial institutions, logistics companies, transportation providers, and freight forwarders) should be aware of Russia's procurement efforts so that they may adopt appropriate measures to counteract sanctions risks.

Background

Items on the common high priority items list are targeted by Russia for procurement. Some of these items are designated in Australian sanctions law as 'export sanctioned goods' for Russia; principally this is goods whose Australian Harmonized Export Commodity Classification (AHECC) codes fall within heading 8207, or chapters 84 and 85 of the AHECC. In addition, the goods may also be 'export sanctioned goods' by virtue of being arms or related matériel for Russia, or because another definition of 'export sanctioned good' applies. It is an offence to supply, sell or transfer goods (that are export sanctioned goods in relation to Russia) to another person, and as a direct or indirect result the goods are transferred to Russia, for use in Russia, or for the benefit of Russia, without a permit.

Australian exporters and related service providers are generally obliged to take reasonable precautions and exercise due diligence to avoid contravening Australian sanctions law. Russia is seeking to circumvent sanctions to procure goods on the common high priority items list, exporters and related services providers should take reasonable precautions and exercise due diligence to ensure that supplying, selling or transferring listed goods to customers in non-sanctioned countries will not result in the goods being transferred to, for use in or for the benefit of Russia. Businesses should consider a range of scenarios that could lead to this result, such as intentional on-forwarding by an end-user who conceals their participation in Russian procurement, and diversion of goods intended for a legitimate end-user by intermediaries.

Businesses can use all items on the common high priority items collectively as a due diligence tool by analysing customer transaction data and developing profiles of high-risk customer activity or high-risk export corridors specific to the business. This may assist businesses to detect and avoid potential sanctions breaches and suspicious customers may be reported to the ASO before they occur.

Users should consider all applicable sanctions measures and seek independent legal advice when considering sanctions compliance risks. This document should only be used as a guide and should not be used as a substitute for legal advice. Users are responsible for ensuring compliance with sanctions laws. You should also consider whether your activities might engage other countries' sanctions laws.

Common High Priority Items