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Exports of Dual-Use Goods to 16 Foreign Entities Restricted

Tuesday, December 29, 2015
Sandler, Travis & Rosenberg Trade Report

The Bureau of Industry and Security has issued a final rule that, effective Dec. 29, adds 16 persons in Cyprus, Luxembourg, Panama, Russia, Switzerland, the United Kingdom and the Crimea region of Ukraine 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 eight entities for materially assisting, sponsoring or providing financial, material or technological support for, or goods and service to or in support of, a senior official of the Russian government or operating in the defense or related materiel sector in Russia. Another eight entities are being added as 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.

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