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Doing business in Ukraine? Use Caution…..

In a recent client engagement our firm advised a company headquartered in a South Asian country which has a U.S. based subsidiary on a case that involves the subsidiary sourcing heavy machine tools out of Ukraine for a client steel mill located in a Southeast Asian country. The Ukrainian origin machine tools were not produced with U.S. origin parts, components, software or technology and the equipment is not located in the United States, nor will it be shipped through the United States. Thus the machinery is not subject to the EAR (had it been U.S. origin it would be classified as 2B999 and controlled for AT reasons only). Nevertheless, our […]