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BIS

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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 Department’s Bureau of Industry and Security (“BIS”) 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 (“EAR”), 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 May 9, 2022, the US Department of Commerce issued a Final Rule (the “Final Rule”) expanding the Russian industry sector sanctions to cover additional items subject to the Export Administration Regulations (the “EAR”) beyond restrictions targeting the Russian energy sector. Under the Russia industry sector sanctions, all items identified in Supplement No. 4 to part 746 of the EAR (“Supplement No. 4”) that are subject to the EAR trigger a licensing requirement when they…

On May 2 and 5, 2022, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued three new and two amended Russia-related General Licenses (“GLs”). OFAC also issued one new Frequently Asked Question (“FAQ”) and amended another. Additionally, Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a tranche of Russia-related FAQs. New General Licenses GL 30 authorizes all transactions involving Gazprom Germania GmbH that are prohibited by Directive 3 under…