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Exports of EAR-Regulated Goods Restricted to Two Russian Entities

Wednesday, December 20, 2017
Sandler, Travis & Rosenberg Trade Report

The Bureau of Industry and Security has issued a final rule adding two entities in Russia to the list of entities restricted from receiving U.S. exports of goods controlled under the Export Administration Regulations. BIS has determined that these two entities produced, for the Russian Ministry of Defense, a ground-launched cruise missile system and associated transporter-erector-launcher with a range prohibited by the Intermediate Range Nuclear Forces Treaty.

For these two entities there is a license requirement for exports, reexports, or transfers (in-country) of all items subject to the EAR 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 either 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.

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