Background

The Bureau of Industry and Security has added Iceland, Liechtenstein, Norway, and Switzerland to a list of 33 others excluded from portions of new U.S. export controls on Russia and Belarus.

In response to Russia’s invasion of Ukraine BIS has added highly-restrictive license requirements and policies for certain transactions involving Russia and Belarus under the Export Administration Regulations. These include two new foreign direct product rules specific to Russia and Belarus and to military end-users in those countries.

These restrictions refer to a list of countries that have committed to implementing substantially similar export controls on Russia and Belarus under their domestic laws. Countries that have made such a commitment receive full or partial exclusions from the FDP rules’ license requirements, and such requirements are not used to determine controlled U.S. content under the EAR’s de minimis rules provided certain criteria are met.

Effective April 8, BIS has added Iceland, Liechtenstein, Norway, and Switzerland to this list with the designation of “full.”

For more information on restrictions on exports to Russia and Belarus, please contact Kristine Pirnia at (202) 730-4964 or via email.

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