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ARTICLE · 08 APRIL 2021

Exporting To Russia? Things Just Got (More) Difficult

Exporting to Russia is already a challenge. There are OFAC sanctions arising out of the Ukraine/Crimea situation, Military End User controls, and the usual export licensing requirements.

RussiaInternational Law

Exporting to Russia is already a challenge. There are OFAC sanctions arising out of the Ukraine/Crimea situation, Military End User controls, and the usual export licensing requirements. Based on the recent exchange between President Biden and Putin, it's obvious that things are not getting any better any time soon regarding our relationship with Russia, and export controls are following suit.

On March 2, 2021, the Bureau of Industry & Security (BIS) announced it was adding 14 entities located in Russia, Germany, and Switzerland to the Entity List. The Entity List is found in Supplement 4 to Part 744 of the Export Administration Regulations. It contains the names of hundreds of entities in many countries that are "reasonably believed to be involved, or pose a significant risk of becoming involved, in activities contrary to the national security or foreign policy interests of the United States." Adding parties to the Entity List requires a finding of such activities

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