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 March 3, adds 91 entities to the Entity List for having been involved in, contributed to, or otherwise supported the Russian security services, military and defense sectors, and military and/or defense research and development efforts. Affected entities include 81 in Russia, three each in the United Kingdom and Estonia, two each in Malta and Spain, and one each in Belize, Kazakhstan, Latvia, Singapore, and Slovakia.

For all of these entities BIS is imposing a license requirement for exports, reexports, and transfers (in-country) of all items subject to the Export Administration Regulations. BIS will review license applications under a policy of denial for all of these entities, except on a case-by-case basis for U.S. government space programs with respect to five of them. 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 March 3 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.

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