New End Use/End User Restrictions for China, Russia, and Venezuela
The Bureau of Industry and Security (BIS) will implement new restrictions on military end use/end users for China, Russia, and Venezuela beginning on June 29. Applications for export, reexport or transfer (in country) items for specific ECCNs for military end use or military end users in these countries will be reviewed with a presumption of denial.
For these restrictions, military end use means: incorporation into a military item described in the U.S. Munitions List; incorporation into items classified under ECCNs ending in A018 or under 600 series or any item that supports or contributes to the operation, installation, maintenance, repair, overhaul, refurbishing, development or production of military items described on the USML or items classified under ECCNs ending in A018 or under 600 series.
Military end user means the national armed services as well as the national guard and national police, government intelligence or reconnaissance organizations, or any person or entity whose actions or functions are intended to support military end uses.
Of particular significance for our clients is the categorization of 9A991 aircraft and gas turbine engines and 9E991 technology as military as being subject to military end use/end user license requirements reviewed with a presumption of denial.
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