On September 9, 2022, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) published an interim final rule (the “2022 IFR”) revising the Export Administration Regulations (“EAR”) to authorize the release of certain technology and software in the context of “standards-related activity” involving entities listed on the Entity List. Comments on the impact of this action on participation in “standards-related activity” must be submitted to BIS no later than November 8, 2022. By…
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…
On June 2, 2022, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) added additional Russian and Belarussian entities to the BIS Entity List, enacted new licensing requirements for food, medicine for military end-users on the Entity List, and stated that they would be making charging letters public in a pair of Final Rules (here and here). We have outlined these developments in additional detail below. Additions of Russian and Belarusian Entities…
On June 27, 2022, President Biden and the other G7 leaders issued a statement on support for Ukraine (“G7 Statement”), in which they vowed to sustain and intensify their coordinated sanctions measures in response to Russia’s war of aggression. The corresponding White House Announcement outlines the actions the Biden Administration planned to take in coordination with the G7, including additional sanctions measures. The following day, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”)…