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ARTICLE · 08 MARCH 2022

New Sanctions And Export Controls For Russia And Belarus, Phase III

Goodwin Procter LLP
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As Russia's invasion of Ukraine continues, the White House countered with another wave of sanctions and export controls.

GlobalInternational Law
Richard Matheny, III
Richard Matheny, III
Jacob R. Osborn
Jacob R. Osborn
Amy S. Josselyn
Amy S. Josselyn
Ce (“Charles”) Li
Ce (“Charles”) Li
Justin C. Pierce
Justin C. Pierce
Gozde Guckaya
Gozde Guckaya

As Russia's invasion of Ukraine continues, the White House countered with another wave of sanctions and export controls.

Building on the restrictions discussed in our Phase I and Phase II alerts, these new measures further deny Russia and Belarus access to U.S.-origin technology, weaken Russia's defense sector, penalize specific entities and officials supporting the invasion, and cut off sources and methods of financing. The rapidly evolving landscape makes it essential for companies to evaluate their touchpoints with Russia, Belarus, and Ukraine.

1. NARROWED SCOPE FOR SOFTWARE EXPORTS TO RUSSIA AND BELARUS

Amendments to the Export Administration Regulations (EAR) effective on March 2 further narrowed License Exception ENC for the export of encryption items controlled under Category 5 of the Commerce Control List (CCL). Absent the license exception, many commercial software items will require an export license before making the software available for download

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