On August 2, 2022, the US Commerce Department’s Bureau of Industry and Security (“BIS”) updated its list of aircraft that have flown into Russia or Belarus in apparent violation of the Export Administration Regulations (“EAR”) (the “List”) by adding 25 foreign-produced aircraft. These aircraft were identified by BIS as subject to the EAR because they incorporate controlled US-origin content exceeding applicable de minimis amounts (i.e., greater than 25% by value) and having apparently violated the…