US Expands Export Restrictions on Russia and Targets Russian Energy Sector


On August 1, 2014, the Bureau of Industry and Security (BIS) announced further export restrictions targeting Russia generally and the Russian oil and gas sector in particular, effective August 6, 2014. This action implements restrictions taken in coordination with further enhancement of sanctions measures against Russia stemming from the Ukraine situation, which were announced generally on July 29, 2014.

Background -

BIS is the agency responsible for administering export controls on items that are subject to the Export Administration Regulations (EAR), including dual-use items. This includes most goods, software and technology originating from the United States, and also some items made outside the United States that incorporate specified levels of US-origin content. If an item subject to the EAR is controlled for export or reexport to a certain country, end-use or end-user, an export license is required absent a license exception. Not all items require export licenses for Russia. Depending on the situation, license exceptions may be available, even if a license would otherwise be required. The export control restrictions effective August 6 increase export licensing requirements for exports and reexports to Russia, as well as certain transfers within Russia...

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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