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New Licensing Requirements for Russia and Belarus

News & Blog

A new rule, effective April 8,2022 expands the license requirements on Russia and Belarus to all items designated on the CCL in Categories 0 through 9. This rule applies the additional restrictions established under previous Russia and Belarus rules to the three categories of unilaterally-controlled technology remaining on the Commerce Control List (CCL). These are Categories 0-2, which include materials and equipment relevant to nuclear, chemical, and materials processing. While the vast majority of items in Categories 0-2 already required a license for Russia and Belarus (or are subject to the licensing authorities of other agencies), this rule imposes new license requirements for items including certain composite materials, medical products containing certain toxins or genetically modified organisms, hydraulic fluids, pumps, valves, and lower-level machine tools.

In connection with this expansion in scope, the rule also applies the new Foreign Direct Product (FDP) Rules for Russia/Belarus and to Russian/Belarusian Military End Users (MEUs) to all items on the CCL. With limited exceptions, BIS will review applications involving all such CCL items under a policy of denial.

Additionally, the rule excludes aircraft registered in, owned, or controlled by, or under charter or lease by Belarus or a national of Belarus from using License Exception AVS (Aircraft, Vessels, Spacecraft). In a prior rule, BIS similarly limited the availability of AVS for aircraft registered in, owned, or controlled by, or under charter or lease by Russia, or by a national of Russia.

This Blog is made available by Wilmarth & Associates for educational purposes as well as to give you general information and a general understanding of export law and compliance, not to provide specific legal advice. This blog is not legal advice and should not be treated as such. You must not rely on this blog as an alternative to legal advice from your attorney or other professional legal services provider. The information provided on this website is presented “as is” without any representations or warranties, express or implied.
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