As flagged in our initial blog, the US Department of Commerceās Bureau of Industry and Security (āBISā) published on February 24, 2022 aĀ public inspection copy of a final ruleĀ (āFinal Ruleā), effective immediately (subject to a very limited savings clause), that implements a sweeping series of export control measures under the Export Administration Regulations (āEARā) against Russia. The press release regarding these new controls can be foundĀ here. The controls are a result of multi-laterally coordinated efforts…
Recently the UK announced that it will suspend all existing export licences for dual-use items to Russia along with the approval of any new export licences for the same purpose. Following this announcement the UK Export Control Joint Unit has removed Russia as a permitted destination from the following open general export licences: open general export licence Xopen general export licence X from December 2019open general export licence chemicalsopen general export licence chemicals from December-2019open…
On February 24, 2022, each of the three Belgian Regions (the Flemish, Walloon and Brussels Regions) announced that all export licenses issued by their services with Russia as destination country or country of end-use will be temporarily suspended. The suspension will be evaluated on a day-to-day basis. The Flemish Strategic Goods Control Unit, which is responsible for issuing licenses for the export of military and dual-use items in the Flemish Region, indicated that for transactions…
On February 21, 2022, the White House issued a new Executive Order that imposes comprehensive sanctions on the so-called Donetsk Peopleās Republic (“DNR”) and Luhansk Peopleās Republic (“LNR”) regions of Ukraine. Concurrently with the issuance of the Executive Order, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) published six general licenses (“GLs”) authorizing certain transactions involving the targeted regions. These sanctions were imposed in response to the Russian Government’s decision to recognize the…