Commerce Department Expands Russia And Belarus Controls, Implements Clarifying Changes

On January 25, 2024, the Commerce Department's Bureau of Industry and Security ("BIS") strengthened its existing controls under the Export Administration Regulations ("EAR") against Russia and Belarus. Specifically, BIS is expanding the list of products under additional U.S. Harmonized Tariff Schedule ("HTS") codes that are restricted for export to Russia or Belarus and by making certain changes to the licensing requirements that apply to the occupied Crimea region of Ukraine. Additionally, BIS further restricted Russia's access to unmanned aerial vehicles supplied by Iran.

BIS added 95 new HTS codes at the 6-digit level to the list of items requiring a license for export, reexport, or transfer (in-country) to Russia or Belarus. The expanded list of items includes certain chemicals, lubricants, and metals, and it covers the entirety of Chapter 88 of the HTS (aircraft, spacecraft, and parts thereof), further restricting Russia's access to inputs for its defense