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

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

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

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

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 6. This post supplements our previous summaries, which are available by following the links at the end of this blog post.

United States Issues Expansive Restrictions on Russian Entities, Expected to Ban New Investment

On April 1, the Commerce Department added 120 entities in Russia and Belarus to the Entity List based on their activities in the Russian and Belarusian defense, aerospace, maritime, and other strategic sectors. Of these entities, 95 are designated military end-users, which makes them subject to the Russia Military End-User Foreign Direct Product Rule (Russia-MEU FDP Rule). As discussed in a previous update, the Russia-MEU FDP Rule significantly broadens U.S. export jurisdiction over items made outside the United States using U.S.-origin technology.

Continue Reading Russia, Ukraine: Update as of April 6

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 1. This post supplements our previous summaries, which are available by following the links at the end of this blog post.

Commerce Department Updates List of Tainted U.S.-Origin Aircraft

On March 30, the U.S. Commerce Department, Bureau of Industry & Security (BIS) issued a press release to update the restrictions and prohibitions it announced on March 18 pertaining to U.S.-origin aircraft operated in violation of the Export Administration Regulations (EAR). Please see our blog post here for more details on that March 18 notice.

Continue Reading Russia, Ukraine: Update as of April 1

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 the evolving situation as of Thursday, March 31 concerning current U.S. sanctions and export restrictions related to Russia and Ukraine. This post supplements our previous analysis all of which are linked at the end of this blog post.

United States Targets Russian Sanctions Evaders in the Latest Round of Designations

On March 31, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced the designation of still more entities and individuals as it expands sanctions against Russia. These parties have been designated as Specially Designated Nationals (SDN); as a general matter, U.S. persons are prohibited from conducting any transaction with an SDN.

Continue Reading Russia, Ukraine: Update as of March 31

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 the evolving situation as of Thursday, March 24 concerning current U.S. sanctions and export restrictions related to Russia and Ukraine. This post supplements our previous analysis all of which are linked at the end of this blog post.

United States Aligns with Allies, Sanctions Hundreds of Russian Lawmakers and Others

On March 24, President Biden announced that the United States will impose sanctions on “over 400 individuals and entities comprised of Russian elites, the Duma and more than 300 of its members, and defense companies.” In so doing, the United States aligns itself with the sanctions efforts of the European Union and G7 (which consists of Canada, Japan, and the UK along with several members of the EU). This continues the unprecedented multilateral effort to restrict trade with and involving Russia.

Continue Reading Russia, Ukraine: Update as of March 24