The OverRuled: BIS Export Controls Module has been updated with the following actions:
- 12 Jun 2024 - Turboshaft FZE; Treetops Aviation; Black Metal FZE; Timur Badr; Elain Balingit - Denial Order; No monetary penalty
On June 12, 2024, BIS issued a Temporary Denial Order against Turboshaft FZE (“Turboshaft”), Treetops Aviation (“Treetops”), Black Metal FZE (“Black Metal”), Timur Badr, and Elaine Balingit (the “Respondents”) for a period of 180 days in relation to violations of 15 C.F.R. §§ 740.15, 746.8 and 766.24. Specifically, the Respondents sought to procure shipment of various U.S. origin commodities, including certain aircraft parts classified as ECCN 9A991.d to Russia, including to parties on the BIS Denied Persons List. BIS did not impose any monetary penalty
- 12 Jun 2024 - SkyTechnic; Skywind International Limited; Hong Fan International; Lufeng Limited; Unical dis Ticaret Ve Lojistik JSC; Izzi Cup DOO; Alexey Sumchenko; Anna Shumakova; Branimir Salevic; Danijela Salevic - Denial Order; No monetary penalty
On June 12, 2024, BIS issued a Temporary Denial Order against Alexey Sumchenko (“Sumchenko”), Anna Shumakova (“Shumakova”), Branimir Salevic (“Branimir”), Danijela Salevic (“Danijela”); SkyTechnic, Skywind International Limited (“Skywind”), Hong Fan International (“Hong Fan”), Lufeng Limited (“Lufeng”), Unical dis Ticaret Ve Lojistik LSC (“Unical”), and Izzi Cup DOO (“Izzi Cup”) (the “Respondents”) for a period of 180 days in relation to violations of 15 C.F.R. §§ 746.8 and 766.24. Specifically, the Respondents sought to procure various U.S.-origin commodities, including aircraft parts classified as ECCN 9A991.d, and transship them to Russia without seeking required authorization from BIS. Some of the parties to the transactions included denied persons on the BIS Denied Persons List. BIS did not impose any monetary penalty.
The OverRuled: Russia Trade Controls Resource Center has been updated with the following actions:
- 12 Jun 2024 (BIS):
The Bureau of Industry and Security (“BIS”) imposed two temporary denial orders ("TDOs") suspending the export privileges of a total of 9 entities and 4 persons associated with two Russian procurement networks.
- 12 Jun 2024 (BIS):
The Bureau of Industry and Security ("BIS") issued a final rule (effective June 12, 2024) amending the Export Administration Regulations ("EAR") to strengthen existing export control restrictions against Russia and Belarus in response to Russia's ongoing war against Ukraine and Belarus' complicity in the war. The final rule amends the EAR to (i) add more export control measures against Russia and Belarus; (ii) consolidate the Russia and Belarus sanctions into a single section in Part 746; (iii) confirms the standard used in connection with actions involving the availability of license exceptions; and (iv) clarifies the scope of various fasteners subject to the Russian and Belarusian industry sanctions.
- 12 Jun 2024 (BIS):
The Bureau of Industry and Security ("BIS") added five entities, one under the destination of Russia and four under the destination of China, to the Entity List for their respective involvement in procuring items subject to the Export Administration Regulations (“EAR”) and for contributing to and supporting Russia’s ongoing war in Ukraine. BIS also amended Section 744.16 of the EAR to now allow BIS to add addresses to the Entity List that present a high risk of diversion, without identifying the name of a party associated with that address, thus triggering a license requirement for all entities who use that address. In connection with this amendment, BIS added eight addresses, all under the destination of China, to the Entity List. These addresses are associated with a significant number of entities, including entities on the Entity List and Unverified List, that are associated with transshipment of sensitive goods to Russia.
The OverRuled: China Trade Controls Resource Center has been updated with the following actions:
- 12 Jun 2024 (OFAC):
The United States sanctioned more than 300 individuals and entities in Russia and outside its borders (including in Asia, the Middle East, Europe, Africa, Central Asia, and the Caribbean) whose products and services enable Russia to sustain its war effort and evade sanctions, pursuant to EO 14024.
In this action, the Department of State designated more than 100 entities and individuals based in the PRC, Hong Kong, Belarus, the United Arab Emirates (UAE), Moldova, Türkiye, Kyrgyzstan, Russia, Singapore, and Liechtenstein. These targets are engaged in the development of Russia’s future energy, metals, and mining production and export capacity; sanctions evasion and circumvention; and furthering Russia’s ability to wage its war against Ukraine.
OFAC concurrently designated nearly 200 entities and individuals across Russia, Belarus, the British Virgin Islands, Bulgaria, Kazakhstan, the Kyrgyz Republic, the PRC, Serbia, South Africa, Türkiye, and the UAE, for: (i) facilitating investment into Russia’s defense industry and acquisition of goods needed to further Russia’s aggression against Ukraine; (ii) laundering gold for a designated Russian gold producer, supporting Russia’s production of unmanned aerial vehicles (UAVs), and procuring sensitive and critical items, such as materials for Russia’s chemical and biological weapons program, anti-UAV equipment, machine tools, industrial machinery, and microelectronics; and (iii) participating in Russia’s development of liquefied natural gas projects.
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