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The U.S. imposed severe export controls on Russia

24 February 2022

The U.S. Commerce Department’s Bureau of Industry and Security (BIS) has imposed several new Russia focused export controls within a Final Rule (Implementation of Sanctions Against Russia Under the Export Administration Regulations [“EAR”]) published on February 24th 2022. The Final Rule that took immediate effect, implements new Russia licensing policies and license requirements. 

These new intensified export controls (under the EAR) apply to a wide range of items and in particular restrict exports of nearly all U.S. items for military end-use and end-users in Russia. Furthermore, due to these new measures, almost all items on the Commerce Control List (“CCL”) now require a license for export to Russia. In addition, the great expansion of the foreign direct product rule (as applied to Russia) caused several more items manufactured out of the U.S. to be subject to the EAR when exported to Russia.

More specifically, some of the new export control measures include 1. The implementation of new license requirements and controls on exports to Russia of items subject the to EAR and detailed in Categories 3-9 of the CCL. 2. The creation of two new Foreign Direct Product Rules for Russia (FDP rules) 3. The enforcement of a licensing policy of denial for items requiring a license under these new controls (except certain license applications that will be reviewed by BIS on a case by case basis). More information on these new controls and measures can be found here.