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USA
Transport ban
Flight ban
Russia
Transport - Aerospace
The U.S. Department of Transportation (“DOT”) issued an order, which: (1) disapproves all of the existing and proposed schedules for combination and all-cargo services filed by PJSC Aeroflot Airlines, AirBridgeCargo Airlines Limited, JSC Aircompany Yakutia, LLC Nord Wind, and Azur Air, L.L.C.; (2) disapproves all prospective proposed schedules that may be subsequently filed by the aforementioned foreign air carriers; and (3) suspends the authority of all Russian foreign civil aircraft operators to navigate aircraft in the United States. Посилання на оригінал

Affected carriers and/or operators may file requests for non-revenue ferry, humanitarian, and/or search-and-rescue operations, which will be considered by USDOT on a case-by-case basis..

02.03.2022
02.03.2022
USA
Trade restrictions
Export control
Russia
Industry - Oil refining + LNG
The rule builds on existing restrictions BIS put in place on the Russian deepwater oil and gas exploration and extraction industries in 2014 by imposing a policy of denial on such items. The new stringent export controls specifically target oil refinery sector to curb exports to Russia of equipment needed to refine oil (a wide variety of items necessary for refining oil) to limit revenue Russia could use to support its military capabilities. Those items covered by the rule are listed in a new Supplement 4 to Export Administration Regulations (EAR) section 746. The new license requirement does not depend on the knowledge of the exporter, but rather applies to all exports, reexports and transfers (in-country) to or within Russia of a long list of items identified in a supplement. These items relate to oil and gas refining and are identified by Harmonized Tariff Schedule (HTS)-6 codes and by the Bureau of Census’s Schedule B numbers. The new rule also adds to existing export restrictions at EAR section 746.5 on exports of certain items that would be used directly or indirectly in Russia's energy sector in the exploration or production of oil and gas in shale, deepwater, or Arctic offshore projects. Посилання на оригінал

Applications for export, reexport, or transfer (in-country) of items that may be necessary for health and safety reasons will be reviewed under a case-by-case license review policy.
License applicants may request emergency processing of license applications.
Exports of items impacted by the rule that were en route aboard a carrier to a port of export, reexport, or transfer (in-country) on March 26, 2022, pursuant to actual orders for reexport, or transfer (in-country) to or within a foreign destination, may proceed to that destination under any previous eligibility for a License Exception or reexport or transfer (in-country) without a license (NLR).

03.03.2022
03.03.2022
USA
Trade restrictions
Import ban
Russia
Energy - Oil
Prohibition on importation into the US of the following products of Russian origin: crude oil; petroleum; petroleum fuels, oils, and products of their distillation; liquefied natural gas; coal; and coal products. Посилання на оригінал
08.03.2022
Дата завершення: not specified
Кінець пільгового періоду: 22.04.2022
08.03.2022
USA
Trade restrictions
Export control
Belarus
Military & related goods
*** Significantly restrict the use of EAR license exceptions; Посилання на оригінал
02.03.2022
02.03.2022
USA
Trade restrictions
Export control
Russia
Industry - Aerospace
The Final Rule also excludes aircraft registered in, owned, or controlled by, or under charter or lease by Russia or a national of Russia from using License Exception AVS (Aircraft, Vessels, Spacecraft). Посилання на оригінал
02.03.2022
02.03.2022
USA
Trade restrictions
Export control
Temporary occupied territories
Comprehensive
The rule imposes comprehensive export controls against DNR and LNR for all items subject to the EAR with few exceptions, such as for food, medicine and certain Internet-based software for personal communications. These new controls generally track the sanctions imposed against the occupied regions and the existing comprehensive embargoes imposed against the Crimea regions of Ukraine in 2014. Посилання на оригінал
02.03.2022
02.03.2022
USA
Trade restrictions
Export control
Belarus
Military & related goods
BIS added Belarus to the scope of two foreign “direct product” rules (FDP rules) that were added to the EAR in the Russia Sanctions rule, making them applicable to Belarus and Belarusian `military end users'. The first FDP rules now relates to both Russia and Belarus. Foreign-produced items subject to the EAR under the Russia/Belarus FDP rule are now subject to the license requirement but are eligible for certain license exceptions. The second FDP rule targets `military end users,' with the revisions made in this rule. Foreign-produced items subject to the EAR under the Russia/Belarus-MEU FDP rule are subject to the license requirement. No license exceptions are available to overcome this license requirement, except as specified in the Entity List entry for a footnote 3 entity on the Entity List in supplement No. 4 to part 744 of the EAR, and such items are subject to a policy of denial for all license applications. Посилання на оригінал

Countries listed in supplement No. 3 have committed to implementing substantially similar export controls on Russia and Belarus under their domestic laws. Therefore, exports or reexports from the countries described in this supplement No. 3 or transfers (in-country) within the countries are not subject to the license requirements. When a license application is required, it is subject to a general policy of denial but will be subject to case-by-case review for certain circumstances described further in § 746.8(b).

02.03.2022
02.03.2022
USA
Trade restrictions
Export control
Belarus
Industry - Aerospace
BIS issued a “Final Rule”, that implements sweeping export controls measures targeting Belarus. These rules, generally, restrict the sale to Belarus of foreign-produced items produced with certain controlled U.S.-origin software or technology. With this final rule, the new sanctions: - Impose new license requirements for items in the Commerce Control List (“CCL”) Categories 3-9, with a licensing policy of denial (except in limited cases) and only limited license exceptions available. Exports, reexports, and transfers (in-country) of all items subject to the EAR and classified in CCL Categories 3-9 now require a license to Belarus (excluding deemed exports and reexports), subject to limited license exceptions and a licensing policy of denial (except in limited cases). CCL Categories 3 through 9 include many items that are not particularly sensitive from an export controls perspective and did not previously require a license to Belarus, such as telecommunications items and low-level encryption items; - Significantly restrict the use of EAR license exceptions related to information security and aviation, including a restriction on license exception AVS, an important authorization for aviation operators; - Specify a license review policy of denial applicable to all of the license requirements on Belarus that are being added in this rule, with certain limited exceptions; - Extension of the two new Foreign Direct Product (“FDP”) Rules imposed on Russia to Belarus and Belarusian military end use/end users (“MEUs”); - Expanded MEU and military-intelligence end use/end users (“MIEU”) restrictions to Belarus; - Addition of two Belarusian Entities to the Entity List as military end-users. The Final Rule has added JSC Integral and the Ministry of Defense of the Republic of Belarus, to the Entity List with a license requirement for all items subject to the EAR; - Impose a license requirement for nuclear nonproliferation items for exports and reexports to Belarus and removes Belarus from Country Group A:4 under the EAR. - expand the existing military end-use and military end-user control scope to include Belarus for all items “subject to the EAR” other than food and medicine designated EAR99 Посилання на оригінал

Items requiring a license under these new controls will be reviewed under a licensing policy of denial, except that the following license applications will be reviewed by BIS on a case-by-case basis to determine whether the transaction would benefit the Belarusian government or defense sector or present a risk of diversion to Russia: related to safety of flight or maritime safety; for civil nuclear safety; to meet humanitarian needs; in support of government space cooperation; for companies headquartered in Country Groups A:5 and A:6 to support civil telecommunications infrastructure; involving government-to-government activities.
The Final Rule narrows License Exception ENC for both Belarus and Russia. Specifically, License Exception ENC is now only available for exports and reexports to, and transfers in, Belarus and Russia for a narrower subset of end-users – i.e., (i) civil end-users that are wholly-owned US subsidiaries, (ii) foreign subsidiaries of US companies that are joint ventures with other US companies, (iii) joint ventures of US companies with companies headquartered in countries from Country Group A:5 and A:6 in supplement, (iv) the wholly-owned subsidiaries of companies headquartered in countries from Country Group A:5 and A:6, or (v) joint ventures of companies headquartered in Country Group A:5 and A:6 with other companies headquartered in Country Groups A:5 and A:6 (“Authorized ENC End-Users“).
The final rule specifies that certain license exceptions for transactions involving Russia similarly apply for transactions involving Belarus. Specifically, the license exceptions that now apply to Belarus are: License Exception TMP for items for use by news media; License Exception GOV; License Exception TSU for software updates for civil end users that are subsidiaries or joint of ventures of companies headquartered in the United States or a country or countries from Country Groups A:5 and A:6; License Exception BAG, excluding firearms and ammunition; License Exception AVS (which now excludes any aircraft registered in, owned, or controlled by, or under charter or lease by Russia or a national of Russia); License Exception ENC, with its eligibility being narrowed; License Exception CCD (which previously only included Cuba and Russia, but now also includes Belarus).
License Exception CCD authorizes specific types of consumer communications devices and software subject to the EAR to be exported or reexported to, or transferred in, Russia or Belarus so long as they are either for independent non-governmental organizations or civilians who are not government officials. Editors of state-run media organizations are considered government officials. The types of authorized items under License Exception CCD are those that are controlled for Anti-Terrorism reasons only and that are consumer computers, consumer disk drives, solid state storage equipment, monitors, printers, modems, network access controllers, communications channel controllers, mobile phones, SIM cards, memory devices, consumer information security equipment, peripherals, digital cameras, televisions, radios, recording devices and consumer software (other than encryption source code) for use with such devices. License Exception CCD is not a general carve-out for all types of items that are consumer devices. It applies only to the devices specifically identified in the exception that fall within the scope of the specific ECCNs noted in the exception.

02.03.2022
03.03.2022
USA
Trade restrictions
Export control
Belarus
Transport - Maritime
BIS issued a “Final Rule”, that implements sweeping export controls measures targeting Belarus. These rules, generally, restrict the sale to Belarus of foreign-produced items produced with certain controlled U.S.-origin software or technology. With this final rule, the new sanctions: - Impose new license requirements for items in the Commerce Control List (“CCL”) Categories 3-9, with a licensing policy of denial (except in limited cases) and only limited license exceptions available. Exports, reexports, and transfers (in-country) of all items subject to the EAR and classified in CCL Categories 3-9 now require a license to Belarus (excluding deemed exports and reexports), subject to limited license exceptions and a licensing policy of denial (except in limited cases). CCL Categories 3 through 9 include many items that are not particularly sensitive from an export controls perspective and did not previously require a license to Belarus, such as telecommunications items and low-level encryption items; - Significantly restrict the use of EAR license exceptions related to information security and aviation, including a restriction on license exception AVS, an important authorization for aviation operators; - Specify a license review policy of denial applicable to all of the license requirements on Belarus that are being added in this rule, with certain limited exceptions; - Extension of the two new Foreign Direct Product (“FDP”) Rules imposed on Russia to Belarus and Belarusian military end use/end users (“MEUs”); - Expanded MEU and military-intelligence end use/end users (“MIEU”) restrictions to Belarus; - Addition of two Belarusian Entities to the Entity List as military end-users. The Final Rule has added JSC Integral and the Ministry of Defense of the Republic of Belarus, to the Entity List with a license requirement for all items subject to the EAR; - Impose a license requirement for nuclear nonproliferation items for exports and reexports to Belarus and removes Belarus from Country Group A:4 under the EAR. - expand the existing military end-use and military end-user control scope to include Belarus for all items “subject to the EAR” other than food and medicine designated EAR99 Посилання на оригінал

Items requiring a license under these new controls will be reviewed under a licensing policy of denial, except that the following license applications will be reviewed by BIS on a case-by-case basis to determine whether the transaction would benefit the Belarusian government or defense sector or present a risk of diversion to Russia: related to safety of flight or maritime safety; for civil nuclear safety; to meet humanitarian needs; in support of government space cooperation; for companies headquartered in Country Groups A:5 and A:6 to support civil telecommunications infrastructure; involving government-to-government activities.
The Final Rule narrows License Exception ENC for both Belarus and Russia. Specifically, License Exception ENC is now only available for exports and reexports to, and transfers in, Belarus and Russia for a narrower subset of end-users – i.e., (i) civil end-users that are wholly-owned US subsidiaries, (ii) foreign subsidiaries of US companies that are joint ventures with other US companies, (iii) joint ventures of US companies with companies headquartered in countries from Country Group A:5 and A:6 in supplement, (iv) the wholly-owned subsidiaries of companies headquartered in countries from Country Group A:5 and A:6, or (v) joint ventures of companies headquartered in Country Group A:5 and A:6 with other companies headquartered in Country Groups A:5 and A:6 (“Authorized ENC End-Users“).
The final rule specifies that certain license exceptions for transactions involving Russia similarly apply for transactions involving Belarus. Specifically, the license exceptions that now apply to Belarus are: License Exception TMP for items for use by news media; License Exception GOV; License Exception TSU for software updates for civil end users that are subsidiaries or joint of ventures of companies headquartered in the United States or a country or countries from Country Groups A:5 and A:6; License Exception BAG, excluding firearms and ammunition; License Exception AVS (which now excludes any aircraft registered in, owned, or controlled by, or under charter or lease by Russia or a national of Russia); License Exception ENC, with its eligibility being narrowed; License Exception CCD (which previously only included Cuba and Russia, but now also includes Belarus).
License Exception CCD authorizes specific types of consumer communications devices and software subject to the EAR to be exported or reexported to, or transferred in, Russia or Belarus so long as they are either for independent non-governmental organizations or civilians who are not government officials. Editors of state-run media organizations are considered government officials. The types of authorized items under License Exception CCD are those that are controlled for Anti-Terrorism reasons only and that are consumer computers, consumer disk drives, solid state storage equipment, monitors, printers, modems, network access controllers, communications channel controllers, mobile phones, SIM cards, memory devices, consumer information security equipment, peripherals, digital cameras, televisions, radios, recording devices and consumer software (other than encryption source code) for use with such devices. License Exception CCD is not a general carve-out for all types of items that are consumer devices. It applies only to the devices specifically identified in the exception that fall within the scope of the specific ECCNs noted in the exception.

02.03.2022
03.03.2022
USA
Financial restrictions
Transaction ban
Russia
Central Bank
Prohibition on US Persons from engaging in any transaction involving the Central Bank of Russia, the National Wealth Fund of Russia, or the Ministry of Finance of Russia, including any transfer of assets to such entities or any foreign exchange transaction for or on behalf of such entities. OFAC added the Directive 4 entities to the Non-SDN Menu-Based Sanctions List, which identifies persons subject to certain non-blocking sanctions. FAQ 1005 mainly addresses the scope of Directive 4 under Executive Order 14024. OFAC amended FAQ 1005 by adding a sentence about the prohibition under the Investment Ban EOs on US persons’ purchase of debt or equity securities issued by Russian entities. Посилання на оригінал
28.02.2022
28.02.2022