Background

As part of an ongoing string of sanctions against Russia in the wake of its invasion of Ukraine, the Bureau of Industry and Security has issued a final rule that, effective April 1, adds another 120 entities in Russia or Belarus to the Entity List for acquiring or attempting to acquire items subject to the Export Administration Regulations in support of the Russian or Belarusian militaries.

For all of these entities BIS is imposing a license requirement for exports, reexports, transfers (in-country), and (for 95 of the entities) exports from abroad of all items subject to the EAR. BIS will review all license applications for these entities under a policy of denial. In addition, no license exceptions are available for covered shipments to these entities.

Shipments of items removed from eligibility for a license exception or for export, reexport, or transfer (in-country) without a license (NLR) as a result of this rule that were en route aboard a carrier to a port of export, reexport, or transfer on April 1 pursuant to actual orders for export, reexport, or transfer to or within a foreign destination may proceed to that destination under the previous eligibility.

For more information on restrictions on exports to persons on the Entity List or other lists, please contact Kristine Pirnia at (202) 730-4964 or via email.

Copyright © 2022 Sandler, Travis & Rosenberg, P.A.; WorldTrade Interactive, Inc. All rights reserved.

ST&R: International Trade Law & Policy

Since 1977, we have set the standard for international trade lawyers and consultants, providing comprehensive and effective customs, import and export services to clients worldwide.

View Our Services 

Close

Cookie Consent

We have updated our Privacy Policy relating to our use of cookies on our website and the sharing of information. By continuing to use our website or subscribe to our publications, you agree to the Privacy Policy and Terms & Conditions.