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US Commerce Department

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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…

On April 8, 2022, in response to Russia’s ongoing aggression in Ukraine, which has been substantially enabled by Belarus, the US Commerce Department’s Bureau of Industry and Security (“BIS”) issued a final rule (“Final Rule”) expanding license requirements for Russia and Belarus under the Export Administration Regulations (“EAR”) to all items on the Commerce Control List (“CCL”). The Final Rule also removes license exception eligibility for aircraft registered in, owned or controlled by, or under charter or…