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”)…
On May 26, 2022, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a final rule (the “Final Rule”) updating the scope of License Exceptions Authorized Cybersecurity Exports (“ACE”) and Encryption Commodities, Software, and Technology (“ENC”) related to cybersecurity items in response to public comments on the interim final rule related to cybersecurity items published on October 21, 2021. The interim final rule established a new control on certain cybersecurity items for…
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…