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