BIS imposes the “China Military End Use Rule” for Exports to Russia

In the ongoing ratcheting up of economic sanctions against the Putin regime it was announced in today’s Federal Register (79 FR 55608 dated September 17, 2014) that the Bureau of Industry and Security is effectively extending the China Military End Use Rule for exports to Russia. In the new rule which becomes effective as of today (September 17, 2014) BIS has amended Part 744.21 of the EAR by adding “Russia” after “Peoples Republic of China” or “PRC” wherever those names appear in this section. What does this mean? In short, a range of ECCN’s that normally for most countries do not require a validated export license, will now require a BIS license if exported, re-exported or transferred to Russia for military end use or to military end users. The common items subject to this new ruling include commercial aircraft parts falling under ECCN 9A991, navigation equipment under ECCN 7A994 and marine cameras falling under ECCN 8A992 among other commercial items listed on the Commerce Control List. The full list of items subject to the new “Russia Military End Use Rule” can be found in Supplement 2 to Part 744 of the U.S. Export Administration Regulations (EAR).

For further information on the new “Russia Military End Use Rule” please contact TSI Global Consulting at 210-757-0618.

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