“As of March 9^th, 2022, this license does not authorize export or re-export of controlled items to parties located in the Russia Federation. For additional information, please see suspension letter dated March 2^nd, 2022”

Above is an updated statement excerpted from previously-issued export licenses for US goods to Russia, in response to Russia’s military action in Ukraine. Further sanctions followed, and are summarized below:

• The Bureau of Industry and Security (BIS) imposed new Commerce Control List-based license requirements for Russia. The final rule added new license requirements for all ECCNs in Categories 3-9. Certain of these items, in 58 ECCNs with unilateral controls, were not previously controlled to Russia and include microelectronics, telecommunications items, sensors, navigation equipment, avionics, marine equipment, and aircraft components. BIS’s restrictions should significantly impact Russia’s ability to acquire items it cannot produce itself.
  
  
  
• OFAC (the Treasury Department’s Office of Foreign Assets Control) imposed expansive economic measures that target the core infrastructure of the Russian financial system, including Public Joint Stock Company Sberbank of Russia (Sberbank) and VTB Bank Public Joint Stock Company (VTB Bank). Measures were implemented that impact all of Russia’s other largest financial institutions and the ability of state-owned and private entities to raise capital, and further bar Russia from the global financial system. The actions also target nearly 80 percent of all banking assets in Russia.
  
  
  
• The Department of Commerce is imposing restrictions on the export of US-origin `luxury goods' worldwide to certain Russian or Belarusian oligarchs and other identified parties. Articles such as liquor, tobacco, make-up, sporting goods, handbags, furs, rugs, clothing, jewelry, and cars (the list is quite comprehensive) are now subject to new licensing requirements, differentiated only by the fact of whether the individual is physically in Russia or Belarus, or whether they are located anywhere else in the world.
  
  
  
• The Russia and Belarus Financial Sanctions Act, clarifying that foreign subsidiaries of U.S. financial institutions must comply with American sanctions against Russia and Belarus, passed out of the House Financial Services Committee March 17 on a voice vote. The Nowhere to Hide Oligarchs' Assets Act, which gives the Financial Crimes Enforcement Network more access to records so that they can "detect Russian oligarchs who are participating in money laundering techniques to hide their money, avoid scrutiny, and evade our sanctions," passed out of the same committee on a 26-23 party-line vote.
  
  
  
• BIS last week released a list of commercial and private aircraft that have violated U.S. export controls by flying into Russia and which require a license for “any form of service.” The agency said it will impose penalties, jail time or loss of export privileges for any company or person that violates the Export Administration Regulations by providing “any form of service” to the aircraft without a required BIS license.
  
  

We will be monitoring these and other US sanctions towards Russia. Many of these sanctions have been replicated by Canada, the United Kingdom, the European Union, and others.

For more information, reach out to our export consultant experts at Tradewin today.