Background

The Bureau of Industry and Security has issued a final rule imposing further controls on exports of industrial and commercial items to Russia and Belarus as of Sept. 15. Specifically, BIS states, this rule:

- expands the scope of the Russian industry sector sanctions to add lower-level items potentially useful for Russia’s chemical and biological weapons production capabilities and items needed for advanced production and development capabilities that enable advanced manufacturing across a number of industries;

- expands the “military end-user” and “military-intelligence end-user” controls by applying the Russian/Belarusian military end-user foreign direct product rule to entities located outside of Russia and Belarus (e.g., in China, Burma, Cambodia, and Venezuela) that were previously added to the Entity List for having continued to supply Russian entities on the Entity List or are under sanctions since Russia’s further invasion of Ukraine;

- expands the scope of the Export Administration Regulations’ industry sector sanctions that currently apply only to Russia to Belarus based on concerns of diversion of sanctioned items from Belarus to Russia; and

- refines existing controls on Russia and Belarus to more closely align with requirements implemented by allies by adding additional dollar value exclusion thresholds for luxury goods.

For more information on the wide range of trade restrictions the U.S. has imposed on Russia and how to ensure your company is in compliance, please contact attorney Kristine Pirnia at (202) 730-4964 or via email.

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