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1150. What does determination of December 22, 2023, “Determination Pursuant to Section 11(a)(ii) of Executive Order (E.O. 14024)” (Russia Critical Items Determination) do?


The Russia Critical Items Determination issued pursuant to subsection 11(a)(ii) of E.O. 14024 identifies certain items that support Russia’s military-industrial base.  Foreign financial institutions (FFIs) may be sanctioned for having conducted or facilitated any significant transaction or transactions, or provided any service, involving Russia’s military-industrial base, including the sale, supply, or transfer, directly or indirectly of these identified items.

FFIs should use the list of specified items for the purpose of mitigating sanctions risk under section 11 of E.O. 14024, as amended.  The broader groups in which these items are categorized provide additional context as to why they are critical for Russia’s war effort, including for the production of advanced precision-guided weapons and other critical items.  OFAC’s Advisory to Foreign Banks on Russia Sanctions Risks provides additional guidance to FFIs on the use of the specified items in the Russia Critical Items Determination and the U.S. Department of Commerce’s Common High Priority Items List.

Russia Critical Items Determination

 Items determined pursuant to E.O. 14024, Sec. 11(a)(ii)
Certain machine tools and manufacturing equipment Numerically controlled (CNC) machine tools
Additive manufacturing (AM) machine tools
Semiconductor manufacturing equipment
Certain manufacturing materials for semiconductors and related electronics Silicon boules
Silicon wafers
Photoresist materials
Bare printed circuit boards (PCBs)
Printed circuit board (PCB) substrates
Certain electronic test equipmentOscilloscopes
Automated test equipment
Data acquisition systems
Signal generators
Pulse generators
Spectrum analyzers
Certain propellants, chemical precursors for propellants and explosivesNitrocellulose 
Smokeless powder
Research Department eXplosive (RDX, also known as Royal Demolition eXplosive, cyclonite, hexogen)  
High Melting eXplosive (HMX, also known as High-Molecular-Weight RDX, octogen, cyclotetramethylenetetranitramine)
Certain lubricants and lubricant additivesTurbine oil 
Turbine oil additives 
Certain bearingsHigh-precision ball and roller bearings
Angular contact (spindle) bearings
Certain advanced optical systemsThermal sights
Thermal imaging arrays
Infrared focal plane arrays
Image intensifier tubes (ITTs)
Certain navigation instrumentsInertial navigation systems (INS)
Inertial measurement units (IMUs)
Fiber-optic gyroscopes (FOGs)
Date Released
December 22, 2023