On February 3, 2022, the Commerce Departmentās Bureau of Industry and Security (“BIS”) published a final rule reorganizing, clarifying, and correcting the traditional and Entity List foreign-direct product rules (“FDP Rules”) in the Export Administration Regulations (“EAR”). This rule does not change the substantive scope of the FDP Rules, but provides certain helpful clarifications. We previously blogged about the FDP Rules here. Reorganization: Consolidation of the FDP Rules into EAR Part 734.9 The FDP Rules…
Under the Russian encryption regulations, notification to, or registration with, the Russian Federal Security Service (the āFSBā) is required in order to import and distribute foreign products (hardware and software) with encryption functions or features in the Russian Federation. Although the FSB is a sanctioned party, listed on the Office of Foreign Assets Control (āOFACā) list of specially designated nationals and blocked persons (the āOFAC SDN Listā) pursuant to the Cyber-Related Sanctions Regulations, 31 C.F.R.…