New U.S. Export Control Requirements for China, Russia, and Venezuela

Posted on June 29, 2020

On Monday, June 29, 2020, new rules went into effect involving the export control of items to China, Russia, and Venezuela. These changes involve when Electronic Export Information (EEI) submission is required, and the elimination of the Civil End Users (CIV) license exception.

AES filing requirements have been strengthened for exports, reexports, and transfers (in-country) for military end-use or military end-users in China, Russia, or Venezuela.

Traditionally exports that are No License Required (NLR) and are under $2,500 USD, have not required EEI to be submitted via AES. This changes with these new rules put in place today. Now, all exports from the U.S. to China, Russia, or Venezuela will require an EEI submission regardless of value, so long as the items to be exported are identifiable on the Commerce Control List (CCL) and aren’t classified as EAR99.   

The second rule change eliminates the license exception for Civil End Users (CIV) for items controlled for national security (NS) reason to Group D countries, which include China, Russia, and Venezuela. Exports that have relied upon this exception in the past will now be subject to licensing requirements. Furthermore, any license requests will most likely be denied, aside from exceptional circumstances.

In summary, companies that export to China, Russia, and Venezuela will be required to bolster processes for AES filing and license exceptions. It would be in the best interest of any exporter to ensure they properly understand these new rules and have taken steps to address the required changes.

For more details or guidance on export controls or any other trade compliance matter, please email Allyn International at  

Contributor: Matthew Dreckman

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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