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 bottom of this page.

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

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…

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 bottom of this page.

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

I recently provided comments for an article in Law.com examining how foreign companies that are continuing to operate in Russia can continue to pay employees while world leaders are imposing economic sanctions making the transfer of funds into Russia difficult. Making the situation more tenuous is the possible retribution that companies or individual employees may face by the Russian government if the company ceases operations entirely.

“We’re trying to read the tea leaves of what the Russian government is most concerned about when they have threatened foreign companies that have halted operations or pulled out of Russia,” I explained in the article. “I’m just not that concerned that Russia thinks, ‘Oh, no, society is going to break down if people can’t buy Coca-Cola anymore.’ But they may be concerned that if Coca-Cola has … 10,000 employees in Russia, and all of a sudden those people are unemployed, that those people … are going to be a threat to social order.”Continue Reading Impact of Economic Sanctions for Russian Companies and Employees

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 bottom of this page.

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 bottom of this page.

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