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Exports of Dual-Use Goods to 29 Foreign Entities Restricted

Thursday, September 03, 2015
Sandler, Travis & Rosenberg Trade Report

The Bureau of Industry and Security has issued a final rule that, effective Sept. 2, adds 29 persons in Cyprus, Finland, Romania, Russia, Switzerland, Ukraine (including its Crimea region) or the United Kingdom to its list of entities restricted from receiving exports of dual-use goods from the United States. BIS states that it is taking this action to ensure the efficacy of existing sanctions against Russia for violating international law and fueling the conflict in eastern Ukraine.

BIS is adding one entity because it is owned or controlled by a person whose property and interests are blocked due to misdeeds in Ukraine; five entities because they are linked to the provision of material support to a person previously designated by the Office of Foreign Assets Control; two entities because they operate in Russia’s arms or related materiel sector; and six entities for operating in the Crimea region of Ukraine. For these entities there will be a license requirement for all items subject to the Export Administration Regulations and a license review policy of presumption of denial. The license requirement applies to any transaction in which items are to be exported, reexported or transferred (in-country) to any of these entities or in which they act as purchaser, intermediate consignee, ultimate consignee or end-user. In addition, no license exceptions are available for exports, reexports or transfers (in-country) to these entities.

BIS is also adding 15 entities that are subsidiaries of a company added to the Entity List in September 2014. For these entities there will be a license requirement for the export, reexport or transfer (in-country) of all items subject to the EAR to those companies when the exporter, reexporter or transferor knows that the item will be used directly or indirectly in exploration for, or production of, oil or gas in Russian deepwater (greater than 500 feet) or Arctic offshore locations or shale formations in Russia or is unable to determine whether the item will be used in such projects. License applications for such transactions will be reviewed with a presumption of denial when intended for such use.

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