New Russian Export Sanctions

The U.S. has announced significant new restrictions on exports to Russia as a response to the invasion of Ukraine.  These new sanctions, effective February 24 include:

1. New license requirements for all ECCN number in categories 3-9 of the CCL, some of which were not previously controlled to Russia. This includes microelectronics, telecommunications items, sensors, navigation equipment, avionics, marine equipment, and aircraft components
2. After review of license applications, the new policy will be able to deny the requests.
3. The new sanctions also expand the military end use scope to all items subject to the EAR.
4. There are new Foreign Direct Product (FDP) Rules: These establish export controls for foreign made items that are the direct product of certain U.S. origin software or technology subject to the EAR or are produced by certain plants or major components that are the direct product of U.S. origin software or technology.
5. There are also new FDP rules for Russian military end-users. Controls are in place for foreign made items that are the direct product of any software or technology subject to the EAR that is on the CCL; or (ii) produced by certain plants or major components thereof which are themselves the direct product of any U.S.-origin software or technology on the CCL.

More sanctions could be implemented as the situation moves forward.  Other countries, such as the UK and Australia, and even the EU, are either considering sanctions or have already implemented some. If you have any questions about how these sanctions may affect your exports to Russia, please contact Allyn at sales@allynintl.com.

Contributor: Matthew Dreckman

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About Allyn International

Allyn International is dedicated to providing high quality, customer centric services and solutions for the global marketplace. Allyn's core products include transportation management, logistics sourcing, freight forwarding, supply chain consulting, tax management and global trade compliance. Allyn clients range from small local businesses to Fortune 500 firms. Allyn conducts business in more than 20 languages and has extensive experience in both developed and emerging markets. Highly trained experts are positioned throughout North and South America, Europe and Asia. Allyn’s regional headquarters are strategically located in Fort Myers, Florida, U.S.A., Shanghai, P.R. China, Prague, Czech Republic, and Dubai, U.A.E. For more information, visit www.allynintl.com.