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Alexander Matthews (USA)

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On May 16, 2022, the Biden administration announced the relaxing of certain limited Cuban sanctions and other regulatory changes to expand communication, travel, and commerce between the United States and Cuba. The related fact sheet can be found here. The US State Department outlined four changes to Cuba policy in the announcement: Facilitate family reunification: The Cuban Family Reunification Parole Program will be reinstated and capacity for consular services and visa processing will continue to…

On May 20, 2022, the US Commerce Departmentā€™s Bureau of Industry and Security (ā€œBISā€) announced the issuance of a temporary denial order denying the export privileges of the airline Rossiya to participate in transactions subject to the Export Administration Regulations (ā€œEARā€), including exports and reexports from the United States. BIS previously issued similar orders covering Aeroflot, Azur Air, UTair, and Aviastar-TU. Aeroflot is a majority shareholder of Rossiya, and both airlines own and operate a number of US-origin aircraft, many requiring US-origin…

On March 18, 2022 and in response to Russia’s invasion of Ukraine, the US Department of Commerceā€™s Bureau of Industry and Security (ā€œBISā€) publicly identified 100 commercial and private aircraft that have recently flown into Russia in apparent violation of the Export Administration Regulations (ā€œEARā€). As summarized in our prior blog posts (see here and here), the US has also issued restrictions that effectively ban any aircraft with a nexus to Russia from using US…

As summarized in our prior post, on March 2, 2022, the US Department of Transportation (USDOT) and Federal Aviation Administration (FAA) issued prohibitions on Russian flight operations in US airspace. On March 2, 2022, the FAA issued a Notice to Air Missions (NOTAM) that prohibited Russian airlines and operators from using US airspace. On March 10, 2022, the FAA issued a revised NOTAM (2/2415) to clarify applicability. The new NOTAM revised the language regarding prohibited…