Effective today (Febrary 24, 2022) the Bureau of Industry and Security has published and implemented sweeping export controls on Russia in response to their invasion of Ukraine. The main elements of these new comprehensive sanctions involve a) requiring a license for any item listed on the Commerce Control List in Categories 3-9 (with license applications subject to a general policy of denial) and 2) expanding the Military End User/End Use controls noted in Part 744.21 of the EAR as applied to exports, re-exports and transfers to Russia which now apply to ALL ITEMS SUBJECT TO THE EAR with the exception of food and medicine designated as EAR99, or ECCN 5A992.d or 5D992.d items unless for Russian government end users or state-owned enterprises. In addition, 45 Russian entities were moved from the military end user (MEU) list to the Entity List (Part 744.11) with an expanded license requirement to all items subject to the EAR when exporting, re-exporting or transferring to such entities. The new regulations, among other things, also add two new foreign direct product rules as applicable to Russia and Russian military end users and apply new comprehensive restrictions, in all essence a complete trade embargo on exports, re-exports and transfers of items subject to the EAR to the so called Donetsk People’s Republic (DNR) and Luhansk People’s Republics (LNR) regions of Ukraine. TSI Global Consulting will provide a more complete write-up and analysis of these newly implemented export controls/comprehensive sanctions in the days to come.
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