In response to Russia’s invasion attempts, the US Commerce Department’s Bureau of Industry and Security (BIS) responded to the Entity List for support by adding fifty seven entities in Russia and the Crimea region of Ukraine. “The Entity List specifies the license requirements that it imposes on each listed person. Those license requirements are independent of, and in addition to, license requirements imposed elsewhere in the [Export Administration Regulations] (EAR).”
In a press release from September 30th, Assistant Secretary of Commerce for Export Administration Thea D. Rozman Kendler said, “The United States and our partners and allies remain resolute in opposing this brutal, unjustified assault and BIS will continue to take action to deny Putin’s regime and those that support it access to global commerce.”
Furthermore, BIS has issued a new FAQ to pertain to part of a September 15th final rule that, according to the federal register, states it’s “expanding the existing sanctions against Russia and Belarus by imposing new export controls, including expanding the scope of the Russian industry sector sanctions to add lower-level items potentially useful for Russia’s chemical and biological weapons production capabilities and items needed for advanced production and development capabilities to enable advanced manufacturing across a number of industries.”
“This ruling also applies to Belarus for Russia-only sector sanctions… and ‘military end user’ as well as ‘military-intelligence end user’ controls and applies the Russian/Belarusian-Military End User Foreign Direct Product (FDP) rule… The latter rule applies to ten existing entries for six existing entities that have continued to supply Russia and in doing so furthering the invasion of Ukraine.” The FDP rule subjects Belarus to the same sanctions as Russia effective Feb. 24, 2022.
According to the National Customs Brokers and Forwarding Associations of America (NCBFAA), “All U.S. parties are required to comply with sanction regulations upon publication, including additions to the BIS Entity List.”
Because of this, and because of the constant additions to the US sanctions lists, here at Sobel we will be consistently checking and updating our software immediately upon publication. We will be following the Consolidated Screening List to ensure we screen shipments for blocked and restricted parties. If you have any questions on whether your cargo may be restricted or blocked, please contact your Sobel representative today.
