The OverRuled: BIS Export Controls Module has been updated with the following actions:
- 20 Sep 2024 - PJSC Aeroflot - Denial Order; No monetary penalty
On September 20, 2024, BIS renewed against PJSC Aeroflot ("Respondent") a Temporary Denial Order (TDO) originally issued on April 7, 2022 (87 Fed. Reg. 21611) for a period of 1 year in relation to violations of the Export Administration Regulations ("Regulations"). Specifically, the Respondent was involved in exporting or reexporting 9A991.b aircraft, among many others, on flights into multiple destinations after March 2, 2022, without the required BIS authorization. Moreover, the continued operation of these aircraft by the Respondent, even on domestic routes within Russia and the company’s ongoing need to acquire replacement parts and components, many of which are U.S.-origin, presents a high likelihood of imminent violations warranting imposition of a TDO.
- 20 Sep 2024 - Azur Air - Denial Order; No monetary penalty
On September 20, 2024, BIS renewed against Azur Air ("Respondent") a Temporary Denial Order (TDO) originally issued on April 7, 2022, (87 Fed. Reg. 21614) for a period of 1 year in relation to violations of the Export Administration Regulations ("Regulations"). Specifically, the Respondent was involved in exporting or reexporting 9A991.b aircraft, among many others, on flights into multiple countries after March 2, 2022, without the required BIS authorization. Moreover, the continued operation of these aircraft by the Respondent, even on domestic routes within Russia and the company’s ongoing need to acquire replacement parts and components, many of which are U.S.-origin, presents a high likelihood of imminent violations warranting imposition of a TDO.
- 20 Sep 2024 - UTair Aviation JSC - Denial Order; No monetary penalty
On September 20, 2024, BIS renewed against UTair Aviation JSC ("Respondent") a Temporary Denial Order (TDO) (originally issued on April 7, 2022) for a period of 1 year in relation to violations of the Export Administration Regulations ("Regulations"). Specifically, the Respondent was involved in exporting or reexporting 9A991.b aircraft, among many others, on flights into Russia after March 2, 2022, without the required BIS authorization. The continued operation of these aircraft by the Respondent, even on domestic routes within Russia and the company’s ongoing need to acquire replacement parts and components, many of which are U.S.-origin, presents a high likelihood of imminent violations warranting imposition of a TDO. BIS further found that such apparent violations were significant and deliberate.
The OverRuled: Russia Trade Controls Resource Center has been updated with the following actions:
- 24 Sep 2024 (BIS):
The Group of 7, which consists of the United States, Canada, France, Germany, Italy, Japan, the United Kingdom, and the European Union (collectively, the "G7"), along with the Global Export Control Coalition ("GECC"), published a new guidance document outlining recommended actions to prevent Russian export control and sanctions evasion. The guidance outlines items of heightened risk of being diverted to Russia, updated red flag indicators and best practices for industry to address these red flags, and screening tools and other resources to assist with due diligence.
- 24 Sep 2024 (EU):
The Group of 7, which consists of the United States, Canada, France, Germany, Italy, Japan, the United Kingdom, and the European Union (collectively, the "G7"), along with the Global Export Control Coalition ("GECC"), published a new guidance document outlining recommended actions to prevent Russian export control and sanctions evasion. The guidance outlines items of heightened risk of being diverted to Russia, updated red flag indicators and best practices for industry to address these red flags, and screening tools and other resources to assist with due diligence.
- 24 Sep 2024 (UK):
The Group of 7, which consists of the United States, Canada, France, Germany, Italy, Japan, the United Kingdom, and the European Union (collectively, the "G7"), along with the Global Export Control Coalition ("GECC"), published a new guidance document outlining recommended actions to prevent Russian export control and sanctions evasion. The guidance outlines items of heightened risk of being diverted to Russia, updated red flag indicators and best practices for industry to address these red flags, and screening tools and other resources to assist with due diligence.
- 20 Sep 2024 (BIS):
BIS again renewed three temporary denial orders ("TDOs") for three Russian airlines: Azur Air, UTair Aviation JSC, and PJSC Aeroflot. The TDOs were last renewed on September 23, 2023, and like the previous TDO renewals for these airlines, these latest renewals extend the TDO for each airline for a period of one year.
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