The OverRuled: Russia Trade Controls Resource Center has been updated with the following actions:
- 05 Sep 2024 (UK):
The UK published The Russia (Sanctions) (EU Exit) (Amendment) (No. 4) Regulations 2024 (the "Regulations"), amending The Russia (Sanctions) (EU Exit) Regulations 2019. The measures amend Regulation 54D concerning Legal Advisory Services, to make clear, amongst other amendments, that the provision of legal advisory services, which may otherwise be restricted by Regulation 54D of the Russia Regulations, are permitted on or in connection with compliance with global sanctions, Russian counter-sanctions, and global criminal law. In parallel, the General Trade Licence, Russia Sanctions – Legal Advisory Services, has been revoked on the basis that this is no longer required. The Regulations took effect on September 6, 2024.
- 05 Sep 2024 (OFAC):
The U.S. Department of the Treasury's Office of Foreign Assets Control ("OFAC") designated two entities and two vessels pursuant to Russia-related Executive Order ("E.O.") 14024. These entities and vessels are associated with U.S.-designated Limited Liability Company Arctic LNG 2, one of Russia's key liquified natural gas projects.
Concurrently, OFAC issued General License ("GL") 108, which authorizes limited safety and environmental transactions involving entities and vessels blocked on September 5, 2024, through 12:01 a.m. Eastern Standard Time on November 6, 2024.
- 23 Aug 2024 (BIS):
The Akin Summary document has now been posted for this action.
The Bureau of Industry and Security ("BIS") issued a new final rule that amends the Russia- and Belarus-related restrictions in the Export Administration Regulations ("EAR") by (1) expanding the scope of the Russia/Belarus Military End User Foreign Direct Product Rule to cover an additional group of entities involved in procuring and diverting items for Russia's and Belarus' defense and intelligence industry; (2) imposing controls on EAR99 operation "software" for computer numerical control ("CNC") machines; and (3) making certain other corrections and clarifications.
- 23 Aug 2024 (BIS):
The Akin Summary document has now been posted for this action.
The Bureau of Industry and Security ("BIS") added 123 entities under 131 entries to the Entity List under the destinations of Canada (1), China (42), the Crimea Region of Ukraine (1), Cyprus (1), Iran (11), Kazakhstan (1), Kyrgyzstan (1), Russia (63), Turkey (8), Ukraine (1), and the United Arab Emirates (UAE) (1). According to BIS, these entities were designated for shipping U.S.-origin and U.S.-branded items to Russia in violation of U.S. export controls or for engaging in other activities contrary to U.S. national security and foreign policy interests. Included among these 123 entities are four address-only entries: Address 01, under the destination of Turkey; and Address 09, Address 10, and Address 11, all under the destination of China.
The OverRuled: China Trade Controls Resource Center has been updated with the following actions:
- 23 Aug 2024 (BIS):
BIS issued a final rule amending the EAR to enhance restrictions targeting Russia and Belarus.
- BIS expanded the Russia/Belarus-Military End User FDP rule so that it also applies to "Russian or Belarusian Procurement Entities" (i.e., an entity that poses a significant risk of involvement in the supply or diversion of items subject to the EAR to procurement networks for Russia's or Belarus's defense industry or intelligence services). Such entities may now be designated on the Entity List with a footnote 3 designation. In connection with this change, the FDP rule was renamed as the "Russia/Belarus-Military End User and Procurement FDP rule."
- BIS also imposed controls on EAR99 operation "software" for computer numerical control ("CNC") machines and made certain other corrections and clarifications.
BIS also designated 123 entities, including 42 in the PRC (three of which are address-only entries), on the Entity List, including for shipping U.S.-origin and U.S.-branded items to Russia in contravention of U.S. export controls. 100 of these entities received a footnote 3 designation. Of these, 42 were "Russian Procurement Entities."
Finally, BIS issued new guidance in the form of FAQs on various topics, including guidance for non-U.S. corporate service providers and on address screening.
- BIS expanded the Russia/Belarus-Military End User FDP rule so that it also applies to "Russian or Belarusian Procurement Entities" (i.e., an entity that poses a significant risk of involvement in the supply or diversion of items subject to the EAR to procurement networks for Russia's or Belarus's defense industry or intelligence services). Such entities may now be designated on the Entity List with a footnote 3 designation. In connection with this change, the FDP rule was renamed as the "Russia/Belarus-Military End User and Procurement FDP rule."
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