The Bass, Berry & Sims international trade team is actively monitoring the situation in Russia and Ukraine and providing real-time advice to clients on managing the situation. This post summarizes new U.S. sanctions and export restrictions as of Monday, May 9. This post supplements our previous summaries, which are available by following the links at the end of this blog post.

Commerce Department Adds to Restrictions, Imposes Licensing Requirements on More Russia Exports

On May 9, the U.S. Commerce Department, Bureau of Industry & Security (BIS) announced further restrictions on exports to Russia of items deemed to support Russian military capabilities. Under the rule, the Commerce Department has introduced licensing requirements on hundreds of items that, prior to the rule, would not have required a license for export to otherwise permitted Russian recipients. The items are classified by both Harmonized Tariff Schedule and U.S. Schedule B number. According to BIS, the action has been taken to more closely align the United States with European Union export restrictions related to Russia.

Continue Reading Russia, Ukraine: Update as of May 9

In a May 4 article published by American City Business Journals’ The Playbook, I offered insight on the opportunities for small businesses to engage with federal contracting and practical steps to get started.

The federal government spent more than $665 billion on contracts in FY2020, and a variety of special programs for contracts are designed to meet the goal of spending at least 23% of all contracting dollars with small business owners.

Continue Reading Opportunities for Small Business within Federal Contracting Space

The Bass, Berry & Sims international trade team is actively monitoring the situation in Russia and Ukraine and providing real-time advice to clients on managing the situation. This post summarizes new U.S. sanctions and export restrictions as of Thursday, May 5. This post supplements our previous summaries, which are available by following the links at the end of this blog post.

Commerce Department Adds to List of Russia/Belarus-Owned Aircraft that Operated in Violation of the EAR

On April 28, the U.S. Commerce Department, Bureau of Industry & Security (BIS) added six more Utair aircraft to its list of aircraft that have flown into Russia and/or Belarus in violation of the Export Administration Regulations (EAR). With these additions, BIS now has 159 aircraft on the list. BIS issued an initial list on March 18 and updated the list on March 30, April 8, April 14, and April 21.

Continue Reading Russia, Ukraine: Update as of May 5

The Bass, Berry & Sims international trade team is actively monitoring the situation in Russia and Ukraine and providing real-time advice to clients on managing the situation. This post summarizes new U.S. sanctions and export restrictions as of Wednesday, April 27. This post supplements our previous summaries, which are available by following the links at the end of this blog post.

Commerce Issues Temporary Denial Order Against Russian Cargo Airline

On April 21, the U.S. Commerce Department, Bureau of Industry & Security (BIS) issued a temporary denial order (TDO) against Aviastar, citing ongoing violations of the comprehensive export controls imposed on Russia by the Commerce Department. Aviastar is headquartered in Moscow and provides various cargo services to Russia. Aviastar joins Russian airlines Aeroflot, Utair, and Azur Air, which are already subject to TDOs. See our April 7 blog on previously issued TDOs.

Continue Reading Russia, Ukraine: Update as of April 27

The Bass, Berry & Sims international trade team is actively monitoring the situation in Russia and Ukraine and providing real-time advice to clients on managing the situation. This post summarizes new U.S. sanctions and export restrictions as of April 18. This post supplements our previous summaries, which are available by following the links at the end of this blog post.

President Biden Extends National Emergency under Executive Order 14024

On April 13, President Biden extended the national emergency declared under Executive Order (EO) 14024 for an additional year due to the harmful foreign activities of the Russian government. EO 14024, as expanded by EOs 14039, 14066, 14068, and 14071, provides the overarching authorization for the U.S. government to take the actions described in our updates.

Continue Reading Russia, Ukraine: Update as of April 18

For a virtual panel discussion on March 23, I shared insight on issues facing in-house counsel relating to the increasing trade restrictions stemming from Russia’s invasion of Ukraine.

While sanctions and export controls have largely focused on Russia to date, companies should also prepare for the possibility of U.S. sanctions against China.  I explained that the U.S. has already put in place “broad authority to start imposing sanctions” against China, and could introduce sanctions and other restrictions to dissuade China from supporting Russia.

Continue Reading Sanctions and Export Compliance Tips for Corporate Counsel Panel on Russia and Ukraine

The Bass, Berry & Sims international trade team is actively monitoring the situation in Russia and Ukraine and providing real-time advice to clients on managing the situation. This post summarizes new U.S. sanctions and export restrictions as of April 11. This post supplements our previous summaries, which are available by following the links at the end of this blog post.

Commerce Expands Export Restrictions Against Russia and Belarus; Adds to List of Countries Exempt from the Foreign Direct Product (FDP) Rule.

On April 9, the U.S. Commerce Department, Bureau of Industry & Security (BIS) announced that it has expanded the license requirement for exports to Russia and to Belarus of Categories 0, 1, and 2 of the Commerce Control List (CCL). BIS also removed Belarus from eligibility for license exception AVS. BIS had previously established a license requirement for Russia and Belarus for categories 3 through 9 of the CCL.  See our posts from February 25 and March 3 on previous license requirements.

Continue Reading Russia, Ukraine: Update as of April 11

While we are still in the first half of 2022, it has already been a busy year in terms of labor and employment developments for government contractors. For any companies doing work for the federal government, whether as prime contractors or as subcontractors, it can be challenging to keep up with the perpetually changing requirements, particularly when the changes occur this quickly.

Continue Reading on HR Law Talk

I recently provided insight for an article in Law360 examining the impacts that the Russian invasion in Ukraine is having on supply chain issues, with a focus on the federal contractor sector. Although Russia is not a major trade partner with the United States, the sanctions issued by the United States and other countries have impacted the global supply chain of goods, with the technology sector particularly affected.

Speaking of the impact of the sanctions, I explained, “You do have a decent number of U.S. companies that get a lot of inputs from Russia and Russian suppliers. And now that’s gotten much harder.” I added, “Some U.S. companies have decided to stop doing business in Russia altogether, even if that affects their supply chains, deciding that the compliance issues and reputational risks aren’t worth it.”

The full article, “Contractors Feel Impact of Russia Trade Disruptions,” was published by Law360 on April 6 and is available online.

The Bass, Berry & Sims international trade team is actively monitoring the situation in Russia and Ukraine and providing real-time advice to clients on managing the situation. This post summarizes new U.S. sanctions and export restrictions as of April 7. This post supplements our previous summaries, which are available by following the links at the end of this blog post.

Commerce Issues Temporary Denial Orders Against Three Russian Airlines

Today, the U.S. Department of Commerce, Bureau of Industry and Security (BIS) issued Temporary Denial Orders (TDOs) denying the export privileges of three Russian airlines – Aeroflot, Azur Air, and UTair.  In announcing this action, BIS stated that the three airlines are continuing to violate comprehensive U.S. export controls imposed on Russia.  The TDOs extend for 180-days and may be renewed.  The TDOs terminate the right of these airlines to participate in transactions subject to the Export Administration Regulations (EAR), including exports from the United States and re-exports from abroad.

Continue Reading Russia, Ukraine: Update as of April 7