Background

The Bureau of Industry and Security identified March 18 dozens of commercial and private aircraft that have flown into Russia in recent weeks in apparent violation of the Export Administration Regulations. BIS states that providing any form of service to these aircraft (e.g., refueling, maintenance, repair, or providing spare parts or services) requires authorization and that without it any person, anywhere (including within Russia) risks violating the EAR. Any such violations would be subject to BIS enforcement actions such as substantial jail time, fines, loss of export privileges, or other restrictions.

BIS states that it has imposed “expansive and stringent” controls on exports of aviation-related items to Russia (effective Feb. 24) and Belarus (effective March 2), including a new license requirement for specified aircraft or aircraft parts.  As a result, any aircraft that is (1) manufactured in the U.S., or (2) manufactured in a foreign country and includes more than 25 percent U.S.-origin controlled content, is subject to a license requirement if destined for Russia or Belarus.

BIS notes that these restrictions apply to any situation in which a person has knowledge that a violation of the EAR has occurred, is about to occur, or is intended to occur in connection with an aircraft or other item subject to the EAR, whether or not such aircraft or other item is included on the list mentioned above.

For more information on these and other restrictions on trade with Russia, please contact Kristine Pirnia at (202) 730-4964 or via email.

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