Industrial Policy & Trade Monitor· 2663 actions· ✨ 89 recent

The US Bureau of Industry and Security (BIS) final rule (89 FR 68544; FR Doc 2024-19130) added 123 entities under 131 entries to the Entity List with destinations Russia (63), China (42), Iran (11), Turkey (8), and one each in Canada, Cyprus, Kazakhstan, Kyrgyzstan, Crimea Region of Ukraine, Ukraine, and the United Arab Emirates. The dominant rationale is Russia-diversion enforcement: Chinese, Turkish and other third-country firms (e.g., MAK Logistics, Megatek Ltd., Wellgo International, AllChips Limited, Chipgoo Electronics) named for supplying U.S.-origin electronics and dual-use items to Russian industry and military, plus designation of large numbers of Russian military manufacturers (e.g., JSC 75 Arsenal, FSE Aleksinsky Chemical Plant) as military end users. License requirement is "all items subject to the EAR" with policy/presumption of denial; case-by-case for EAR99 food and medicine to certain Russian military end users. Effective on publication 2024-08-27.

BIS final rule (FR Doc 2024-19132, 89 FR 68539, published 27 August 2024) expanding the Russia/Belarus-Military End User (MEU) Foreign-Direct Product (FDP) rule under the Export Administration Regulations so that it also applies to transactions involving Entity List entries posing a significant diversion risk to Russia's and Belarus's defense industry or intelligence services — the rule is renamed accordingly. The rule also imposes new export, reexport, and in-country transfer controls on software for the operation of computer numerical control (CNC) machine tools destined for Russia or Belarus, and makes corrections eliminating obsolete cross- references introduced by the BIS 25 January 2024 and 18 June 2024 Russia/Belarus final rules. Effective 27 August 2024, except amendatory instruction 11 effective 16 September 2024.

The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) issued a final rule amending three sanctions programs. The rule adds a new general license at 31 CFR § 525.512 to the Burma Sanctions Regulations authorizing the provision of agricultural commodities, medicine, medical devices, replacement parts and components for medical devices, and software updates for medical devices to individuals whose property and interests in property are blocked. It also updates the authorities section of the Burma Sanctions Regulations to reflect recent legislation, replaces "the Office of Foreign Assets Control" / "the Director of the Office of Foreign Assets Control" with the acronym "OFAC" in three sections of the Sudan Stabilization Sanctions Regulations, and corrects a cross-reference in the Ukraine-/Russia- Related Sanctions Regulations. The rule is effective on publication.

The US Treasury's Office of Foreign Assets Control (OFAC) published in the Federal Register reporting instructions implementing Section 104(a) of the Rebuilding Economic Prosperity and Opportunity (REPO) for Ukrainians Act (P.L. 118-50, Division F, enacted April 24, 2024). All US financial institutions at which Russian sovereign assets are located — or that know or should know of such assets, including in correspondent or payable-through accounts — must report those holdings to OFAC using Form TD-F 93.09. Initial reports were due by August 2, 2024, with rolling reports required within 10 days of detecting newly identified Russian sovereign assets. The notice is the predicate step for any future US seizure or transfer of frozen Russian central bank, National Wealth Fund, or Russian Ministry of Finance assets to benefit Ukraine.

The US Bureau of Industry and Security (BIS) final rule (89 FR 55033; FR Doc 2024-14635) added six entries to the Entity List under the destinations of the People's Republic of China (2), South Africa (1), the United Arab Emirates (2), and the United Kingdom (1). The two PRC-based entries (Global Training Solutions Limited; Smartech Future Limited) were added for ties to an existing Entity List party and for training elements of the PRC military. The two UAE-based entries (Mega Fast Cargo LLC; Mega Technique General Trading) were added for repeated dilatory or evasive conduct during BIS end-use checks, including the provision of false, misleading, or incomplete information. The South Africa and United Kingdom entries were added for shipping or attempting to ship US export-controlled items to Russia in violation of EAR controls. License requirement is "all items subject to the EAR" with policy of presumption of denial. The rule is effective on publication, 2024-07-03.

The Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) by adding 13 persons to the Unverified List (UVL) and removing 8. Additions are under five destinations: China (8), Türkiye (2), Cyprus (1), Kyrgyzstan (1), and the United Arab Emirates (1). Removals span China (6), UAE (1) and Russia (1). The single Russian entry (EFO Ltd.) was removed from the UVL because BIS simultaneously moved it to the Entity List, allowing BIS to delete Russia entirely as a UVL destination. UVL placement does not impose a license-denial presumption (unlike the Entity List) but suspends EAR license exceptions for shipments to listed parties and requires US exporters to obtain a signed UVL Statement before exporting items subject to the EAR. Published and effective the same day, 3 July 2024 (89 FR 55036, FR Doc 2024-14642).

On 24 June 2024 the Council of the European Union adopted Council Regulation (EU) 2024/1745, the 14th package of restrictive measures against Russia, amending Regulation (EU) 833/2014. The package introduces the EU's first targeted measures against Russian LNG (a ban on EU-port transhipment to third countries after a 9-month transition, and a prohibition on EU investment and goods/services exports to Russian LNG projects under construction such as Arctic LNG 2 and Murmansk LNG), bans EU entities outside Russia from using the SPFS Russian financial-messaging system, designates 27 named "shadow-fleet" tankers under a new vessel-specific port-access ban, and imposes a "best-efforts" obligation on EU parents to ensure non-EU subsidiaries do not engage in sanctions circumvention. It adds 116 new listings (69 individuals, 47 entities), including third-country circumvention enablers, to the asset-freeze and travel-ban regime.

The Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) by adding three Kaspersky entities to the Entity List under End-User Review Committee (ERC) determinations — AO Kaspersky Lab (Moscow), OOO Kaspersky Group (Moscow), and Kaspersky Labs Limited (London). All three are designated for cooperation with Russian military and intelligence authorities in support of Russian government cyber-intelligence objectives. Exports, reexports, and in-country transfers of all items subject to the EAR to the three entities now require a BIS licence reviewed under a policy of presumption of denial, with no licence exceptions available. The action is paired with a same-week Commerce ICTS final determination prohibiting Kaspersky cybersecurity and anti-virus software transactions in the United States.

BIS final rule (FR Doc 2024-13148, 89 FR 51644, RIN 0694-AJ87) expanding the Export Administration Regulations' Russia and Belarus sanctions architecture. Effective 12 June 2024 (most provisions) and 16 September 2024 (the EAR99 enterprise-software paragraph at §746.8(a)(8)), the rule introduces a new licence requirement for thirteen named categories of EAR99 enterprise software (ERP, CRM, BI, SCM, EDW, CMMS, project management, PLM, BIM, CAD, CAM, ETO) destined for Russia or Belarus; permits address-only Entity List designations to capture high-diversion addresses; adds eight Hong Kong addresses to the Entity List; and refines the Russia/Belarus Industry Sector Sanctions and Foreign Direct Product (FDP) rule. Released the day before the G7 Italy summit alongside coordinated OFAC, State, and Treasury actions that together designated 300+ persons and entities.

Presidential Decree No. 442 of 23 May 2024 establishes a special judicial-administrative procedure by which the Russian Federation or the Central Bank of the Russian Federation can claim, before a Russian court, that an "unjustified deprivation" of Russian sovereign property has been effected by a state body or judicial authority of the United States — and, on a court finding to that effect, receive equivalent-value US-affiliated property located in Russia (real assets, securities issued by Russian companies, cash held in Russian bank accounts, and other property rights) by way of compensation. The mechanism is an explicit reciprocal counter-instrument to the US REPO for Ukrainians Act (Title II of H.R.815, signed 24 April 2024) authorising US executive confiscation of immobilised Russian sovereign assets in US jurisdiction. The decree is structurally extensible: by separate presidential decision, the same procedure may be applied to any other state Russia designates as "unfriendly". Implementing procedural acts and amendments to Russian legislation were required to be adopted by 23 September 2024.

President Biden signed into law on 13 May 2024 the Prohibiting Russian Uranium Imports Act (Division H of the National Security Supplemental Appropriations Act, Public Law 118-50). The law bans imports to the United States of unirradiated low-enriched uranium (LEU) produced in Russia or by Russian state entities, effective immediately, with a waiver mechanism allowing the Department of Energy to grant case-by-case exceptions through 2027 where no alternative supply is available. The law also authorised up to $2.72B to support US uranium enrichment capacity via CENTRUS and allied enrichment partnerships.

The US Bureau of Industry and Security (BIS) final rule (89 FR 41706; FR Doc 2024-10485) added 37 entities under 37 entries to the Entity List, all listed under the destination of the People's Republic of China. BIS designated these parties for one or more of three rationales: (i) shipping US-controlled items to Russia in violation of EAR controls, (ii) attempting to acquire US-origin items to support China's military modernisation or quantum-technology capabilities, and (iii) ties to the PRC high-altitude balloon that overflew the United States in late January–early February 2023. The designations span PRC technology companies (predominantly quantum-computing firms), manufacturing companies, and research institutes. License requirement is "all items subject to the EAR" with a policy of presumption of denial and no license exceptions available. The rule is effective 2024-05-09, with publication in the Federal Register on 2024-05-14.

The Bureau of Industry and Security (BIS) issued a final rule amending the Russia and Belarus sanctions under the Export Administration Regulations (EAR) to add License Exception Medical Devices (MED) at 15 CFR 740.23. The new exception authorises, without an individual licence, exports, reexports, and in-country transfers of EAR99 medical devices and EAR99 parts/components/accessories for exclusive use with such devices to Russia, Belarus, the temporarily occupied Crimea region of Ukraine, and the other covered regions of Ukraine. The exception carries verification conditions and excludes Entity List / military end-user recipients, "production" facilities, and any case where the exporter has knowledge the items will be diverted to weapons production.

The Bureau of Industry and Security (BIS) issued a final rule (FR Doc 2024-08622; Docket 240417-0112; 89 FR 30119) amending the Export Administration Regulations (EAR) to expand the product scope of two Foreign Direct Product (FDP) rules — the Iran FDP rule and the Russia/Belarus/Temporarily occupied Crimea region of Ukraine FDP rule in 15 CFR 734.9(f) — to cover the entirety of the Common High Priority List (CHPL), an HTS-6 list developed jointly with the EU, Japan and the UK that identifies items used in Russian weapons production. The CHPL scope adds basic commercial-grade microelectronics (integrated circuits, RF transceiver modules), test/manufacturing equipment for electronic components, and CNC machine tools to the perimeter, requiring a BIS licence when these foreign-produced items are exported, reexported or transferred to Iran, Russia, Belarus or occupied Crimea. The rule was issued in response to Iran's 13 April 2024 attack on Israel and Iran's ongoing military support for the Russian war in Ukraine; it became effective 18 April 2024 (Federal Register publication 22 April 2024) with a transit grace period for in-flight shipments until 20 May 2024.

OFAC issued two determinations under Executive Orders 14068 and 14071 banning the import into the United States of Russian-origin aluminum, copper, and nickel produced on or after April 13, 2024, and separately prohibiting the provision of warranting/deliverable services for these metals on global exchanges (LME, CME) and their use to settle over-the-counter derivative contracts. Metal produced before the effective date is grandfathered. The action was coordinated with the United Kingdom, which imposed parallel exchange-listing prohibitions the same day, following G7 statements on reducing Russia's metals revenue.

The US Bureau of Industry and Security (BIS) final rule (89 FR 25503; FR Doc 2024-07760) added 11 entries to the Entity List under China (6), Russia (3), and the United Arab Emirates (2), effective 2024-04-11. The primary rationale for the Russia and UAE tranches — and at least one China entity (Shenzhen Jiasibo Technology) — is procurement of US-controlled dual-use aerospace and UAV components for Iran's Shahed- series UAV programme via the Iran Aircraft Manufacturing Industrial Company (HESA); those drones have been used against oil tankers in the Middle East and deployed by Russia in Ukraine. The remaining five China entities were designated for acquiring US-origin items to support China's military modernisation. The rule also adds one alias to the existing entry for Shanghai Biren Intelligent Technology Co., Ltd. This action was the first Entity List final rule published after BIS implemented the 50 Percent Rule for controlling foreign subsidiaries of listed entities.

On 5 April 2024 Japan's Cabinet adopted an amendment to the Export Trade Control Order, following a 1 March 2024 Cabinet understanding, extending the export prohibition on goods that strengthen Russia's industrial base. The additional goods span parts of HS chapters 27 (mineral fuels and oils), 28 (inorganic chemicals), 39, 73, 81 (tungsten powder, molybdenum, cobalt, zirconium, rhenium), 82, 84, 85 (including lithium-ion and nickel-metal-hydride batteries), 89 and 90, with the specific goods fixed by ministerial ordinance and notices issued on 10 April. The export ban applies from 17 April 2024. A separate METI notice bans imports of non-industrial diamonds of Russian origin from 10 May 2024, regardless of port of shipment.

On 29 February 2024 Switzerland's WBF decided to align with the EU's 13th Russia sanctions package by amending the Ordinance on Measures in Connection with the Situation in Ukraine (SR 946.231.176.72), effective 1 March 2024 at 18:00 CET. The amendment adds over 100 individuals and nearly 90 entities — mainly Russian military-industrial-complex firms and suppliers of DPRK-sourced weapons to Russia — to the asset-freeze and designation lists, and extends the dual-use/military-technology export ban to 27 additional companies believed to be circumventing existing controls.

The US Bureau of Industry and Security (BIS) final rule (89 FR 14385; FR Doc 2024-03969; Docket 240215-0050; RIN 0694-AJ54) added 93 entities under 95 entries to the Entity List, effective 23 February 2024, with destinations Russia (63), Turkey (16), China (8), UAE (4), Kyrgyzstan (2), India (1), and South Korea (1). The dominant rationale is enforcement of Russia-diversion controls: 46 Russian defense manufacturers are designated as military end users acquiring US-origin items for Russia's armed forces, five Chinese entities (including Dennex Enterprises Limited and Shenzhen Speed Industrial Materials Co.) are cited for facilitating diversion of controlled microelectronics to Russia, and 16 Turkish firms are cited as procurement hubs obtaining US-origin items of importance to Russia's war effort. Four UAE entities are designated for transshipment networks serving both Russia and Iran. All entities are subject to a presumption of denial for EAR-controlled items; Russian military end users are additionally subject to the Russia/Belarus FDP rule (15 CFR 734.9(g)).

On 23 February 2024, two years after Russia's full-scale invasion of Ukraine, the Council of the European Union adopted Council Regulation (EU) 2024/745, amending Regulation (EU) No 833/2014 and comprising the EU's 13th Russia sanctions package. It adds new CN codes to the export-ban annexes (dual-use and advanced-technology goods) and adds 27 entities — including firms based in China, Hong Kong, India, Sri Lanka, Serbia, Kazakhstan, Thailand and Turkiye — to the list of parties barred from any exemption from the export ban, on the basis they are assessed to be supporting Russia's military-industrial complex via circumvention routes. Asset-freeze listings (106 individuals, 88 entities) under the parallel Council Decision took effect 23 February 2024; the sectoral trade measures took effect 24 February 2024.

Canada made SOR/2024-32, Regulations Amending the Special Economic Measures (Russia) Regulations, registered and effective 2024-02-21 on the second anniversary of Russia's invasion of Ukraine. The regulations add 163 persons to Schedule 1 — 10 individuals and 153 entities, predominantly Russian organizations tied to military-industrial production, logistics, insurance and oil-sector support — triggering Canadian dealing/asset bans. A parallel amendment to Schedule 7 adds five new goods categories under the Harmonized System (explosives and pyrotechnics; data-processing units and components; ball and roller bearings; semiconductor manufacturing equipment; optical and navigational instruments), banning their export to Russia or Russian persons.

MOTIE brought the 33rd amendment of the Public Notice on Trade of Strategic Items into force on 24 February 2024 (announced 20 February 2024), adding 682 items to the Russia/Belarus situational-licence (상황허가) list, taking that list to 1,159 items. The added items span construction machinery, secondary batteries, machine tools and aircraft components judged to have high military-diversion potential. Situational- licence items are prohibited from export in principle from the effective date, with narrow exceptions such as pre-existing contracts and case-by- case review categories.

On 31 January 2024 Switzerland's Federal Council decided to align with the EU's 12th sanctions package (adopted 18 December 2023) by amending the Ordinance on Measures Relating to the Situation in Ukraine (SR 946.231.176.72), entering into force the same day at 18:00. The update extends Switzerland's Russia-sanctions perimeter to match the EU's additions — including the Russian diamond, steel and other import-revenue restrictions — and adds a new financial-sector prohibition barring Russian nationals and Russia-resident individuals from controlling Swiss crypto-asset service providers, aimed at closing sanctions-circumvention and enforcement gaps.

BIS final rule (FR Doc 2024-01408, 89 FR 4804, effective 23 January 2024) strengthens the EAR sanctions architecture against Russia and Belarus by adding 94 HTS-6 entries to the Russian and Belarusian Industry Sector Sanctions (§746.5/§746.8) — covering hand tools, parachutes, aircraft training simulators, and airplane/helicopter components — and expands the de minimis threshold for foreign-made goods incorporating US-origin 600-series and 9×515 items destined for Russia or Belarus. A parallel provision targets Iran's supply of unmanned aerial vehicles (UAVs) to Russia by adding HTS code 852910 (antennas and antenna reflectors) to the §746.7 Iran export-control list. The rule also refines Crimea licensing to permit exports supporting Ukrainian Armed Forces deployments in occupied territories.

The Council of the EU adopted Council Regulation (EU) 2023/2878 of 18 December 2023, the EU's 12th sanctions package against Russia, entering into force 19 December 2023. The package introduces a direct EU import ban on Russian non-industrial natural and synthetic diamonds and diamond jewellery effective 1 January 2024, followed by a phased indirect ban on Russian diamonds processed in third countries (from 1 March 2024, complete by 1 September 2024), developed as part of a G7-coordinated diamond restriction. The package also extends import bans on steel and other products generating significant revenue for Russia, and adds further trade and economic restrictions.

The Russia (Sanctions) (EU Exit) (Amendment) (No. 4) Regulations 2023 (SI 2023/1364) amend the Russia (Sanctions) (EU Exit) Regulations 2019 to prohibit UK persons from acquiring, importing, supplying or delivering listed Russian-origin metals and metal articles, delivering the Prime Minister's commitment to ban Russian copper, nickel and aluminium. Per law-firm summaries the list (a new Schedule 3BA) also covers lead, zinc, tin, tungsten, molybdenum, tantalum, magnesium, cobalt, antimony, manganese and further metals, and most provisions took effect on 15 December 2023 with a grace period for cargoes consigned before that date.

The Bureau of Industry and Security (BIS) added 42 entities under 44 entries to the Entity List, effective December 7, 2023. The majority — 28 entities in Russia — are sanctioned for procuring or contracting on behalf of Russia's defense sector, including avionics, military-grade drones, and military electronics. Fourteen additional entities across Armenia, Belarus, Belgium, Cyprus, Germany, Kazakhstan, the Netherlands, China, and the UAE were added for operating diversion and transshipment networks that supply U.S.-origin items to Russian military end-users. All listed entities face a license requirement for all EAR-controlled items with a presumption of denial.

The Bureau of Industry and Security amended the Export Administration Regulations by adding four entities under nine entries to the Entity List, effective November 21, 2023 (FR Doc. 2023-25684). Three entities — Aerofalcon S.L. (Spain), Novax Group S.A. (Costa Rica, Ecuador, Panama, Russia, Venezuela), and Zero Waste Global SA (Panama, Venezuela) — were listed for circumventing US sanctions by supplying Nicolás Maduro's government with US-origin aircraft parts using fraudulent export documentation. A fourth entity, Si2 Microsystems Private Limited (India), was listed for supplying Russian defense-sector consignees with US-origin integrated circuits in violation of Section 746.5(a)(1)(ii) Russia/Belarus export restrictions. All entities are subject to a license requirement for all EAR items with a presumption of denial.

The Bureau of Industry and Security (BIS) added thirteen entities to the Entity List effective November 2, 2023 — twelve in Russia and one in Uzbekistan — for posing a significant risk of supporting Russia's war against Ukraine through the procurement, development, and proliferation of unmanned aerial vehicles (UAVs). The designated group includes ZALA Aero Group, the Kalashnikov Concern-linked maker of the Lancet loitering munition and Orlan-10 reconnaissance drone. A license requirement now applies to all items subject to the EAR exported, reexported, or transferred to these parties, with a license review policy of denial for everything except food and medicine designated EAR99 (case-by-case), and the Russia/Belarus Military End User Foreign Direct Product rule applies.

BIS added 28 entities to the EAR Entity List across seven countries, targeting four distinct threat clusters: a Russia GRU/UAV diversion network spanning China, Finland, Germany, and Russia; an Iran Shahed-series UAV procurement chain operating through Chinese front companies (designated under the Russia/Belarus Military End User FDP Rule); Pakistan-linked suppliers procuring for unsafeguarded nuclear activities; and two Oman-based entities supporting Yemen's Houthi forces. Russia's dominant titanium producer VSMPO-AVISMA was also added as a military end user. One Chinese entity (Zhejiang Perfect New Material) was simultaneously removed from the Military End User List.

The Bureau of Industry and Security (BIS) removed 35 persons from the Unverified List (UVL) effective 22 August 2023, spanning seven destinations: 27 entities in China, plus one each in Indonesia, Singapore, Turkey, and UAE; two in Pakistan; and two Russian entities removed as a conforming change after being escalated to the more restrictive Entity List. The 33 cooperative removals follow successful completion of end-use checks verifying each party's bona fides under §744.15(c)(2) of the EAR. Removal restores eligibility for EAR license exceptions and eliminates the UVL Statement requirement for US exporters shipping EAR-subject items to these parties.

On 16 August 2023 the Swiss Federal Council amended the Ordinance of 4 March 2022 on Measures in Connection with the Situation in Ukraine (SR 946.231.176.72), aligning with the EU's 11th Russia sanctions package. The amendment adds two UAE-headquartered firms to the list of entities barred from exemptions to Switzerland's dual-use export ban on Russia, restricts the sale of securities issued after 6 August 2023 to Russian nationals, residents, entities and businesses regardless of currency, and adds 12 individuals and 87 entities to the asset-freeze list, targeting dual-use/military-tech exporters, FSB-licensed IT firms, propagandists and government officials. It entered into force the same day at 18:00 CEST.

On 28 July 2023 Japan's government decided a further amendment to the Export Trade Control Order under the Foreign Exchange and Foreign Trade Act, adding goods that contribute to strengthening Russia's industrial base to the existing export prohibition list. The additional goods include passenger vehicles over 1,900cc displacement (gasoline, diesel, hybrid, plug-in hybrid and electric), stainless-steel drill pipes used in oil and gas drilling, yachts and recreational/sporting vessels, and construction-mineral products (monumental/building stone, gypsum, anhydrite, clays). The measure was gazetted 2 August 2023 and took effect 9 August 2023, aligning Japan's export-control list with equivalent measures other G7 members had already adopted.

Poland's Minister of Development and Technology, Waldemar Buda, established a temporary compulsory administrator (tymczasowy zarządca przymusowy) over the Grupa Azoty S.A. shares held by sanctioned Russian oligarch Vyacheslav Kantor through three holding vehicles — Norica Holding S.à r.l. (Luxembourg), Opansa Enterprises Limited and Rainbee Holdings Limited (both Cyprus) — which together controlled 19.82% of the state-linked fertiliser and chemicals group, worth over PLN 0.5bn. The ministry cited Kantor's inclusion on Poland's sanctions list and the protection of the country's economic and energy security, and stated its intent to find a buyer for the stake and compensate Kantor. The Provincial Administrative Court in Warsaw (WSA) later overturned the decision establishing the administration; the ministry did not appeal, and the ruling became final around 30 July 2024, ending the administrator's mandate — though the underlying EU/Polish sanctions on Kantor continue to freeze his ability to exercise any rights attached to the shares.

On 23 June 2023 the Council of the European Union adopted Council Regulation (EU) 2023/1214, amending Regulation (EU) No 833/2014 and comprising the EU's 11th Russia sanctions package. It extends the list of goods generating significant revenue for Russia subject to import bans, adds further export-ban categories (including additional industrial goods, dual-use and advanced-technology items), and introduces a new anti-circumvention tool (Article 12g) allowing the EU to restrict exports of specified sanctioned goods and technology to third countries assessed as high-risk transshipment routes for Russia. Asset-freeze listings under the parallel Council Decision took effect 23 June 2023; the sectoral trade measures took effect 24 June 2023.

Regulation (EU) 2023/1115, adopted 31 May 2023 and in force 29 June 2023, requires all EU operators and traders placing seven in-scope commodities and their derived products on the EU market — or exporting them from the EU — to file due-diligence statements certifying that goods are deforestation-free (no land cleared after 31 December 2020) and produced in compliance with the relevant legislation of the country of origin. A Commission-administered risk-classification system assigns producer countries to low, standard, or high-risk tiers with differentiated due-diligence burdens. Application was subsequently postponed twice: to 30 December 2026 for large operators (Reg (EU) 2024/3234 and Reg (EU) 2025/2650).

The Bureau of Industry and Security (BIS) issued a final rule on 19 May 2023 strengthening existing Export Administration Regulations (EAR) sanctions against Russia and Belarus. The rule expands the Foreign Direct Product (FDP) rule — which applies EAR jurisdiction to foreign-made items produced with US technology or equipment — to cover the temporarily occupied Crimea region of Ukraine. It also revises controls targeting Iran's supply of unmanned aerial vehicles (UAVs) to Russia, closing loopholes identified in prior rounds of Russia-Ukraine-related export-control rulemaking.

The Bureau of Industry and Security (BIS) added 71 entities to the Entity List effective May 19, 2023, as part of the continuing US export-control response to Russia's invasion of Ukraine. Of the 71 additions, 69 are Russian entities (aircraft repair plants, ammunition and gunpowder manufacturers, shipyards, tractor and automobile factories, and engineering centres), one is Armenian, and one is Kyrgyz — the latter two for facilitating diversion of controlled goods to Russia. The majority of Russian entities received "footnote 3" designations as Russian or Belarusian military end users, triggering the Russia/Belarus Military End-User FDP Rule and subjecting them to a license review policy of denial.

MOTIE finalised the 31st amendment of the Public Notice on Trade of Strategic Items on 24 April 2023, effective 28 April 2023, adding 741 items to the Russia/Belarus situational-licence (상황허가) list. The added items span industrial machinery, petroleum and gas refining equipment, steel, chemicals, automotive goods and quantum computers judged to have high military-diversion potential. MOTIE stated the amendment brings Korea's export-control coverage of Russia/Belarus closer to that of the US, EU and Japan, incorporating 2022 international export-control-regime agreements and reflecting the US's 2nd-6th Russia sanctions rounds and a substantial part of the EU's measures.

The Bureau of Industry and Security (BIS) added 28 entities under 32 entries to the Entity List effective April 12, 2023, targeting front companies and logistics networks attempting to evade US export controls to acquire US-origin items in support of Russia's military and defense industrial base. Twelve of the entities are Chinese electronics and semiconductor distributors operating as procurement intermediaries; ten are Russian logistics and trading firms; six are spread across Armenia, Malta, Singapore, Spain, Syria, Turkey, UAE, and Uzbekistan as diversion facilitators. All listed entities are subject to a license review policy of denial for virtually all EAR-controlled items.

The Bureau of Industry and Security (BIS) added eleven entities across Burma, China, Nicaragua, and Russia to the Entity List, effective March 28, 2023, under a human rights foreign policy rationale. Three Burmese trading companies and two Russian aviation-parts suppliers were designated for selling, procuring, and servicing military equipment enabling the Burmese military regime's attacks on civilians; five Xinjiang-based electronics manufacturers were added for activities contrary to U.S. foreign policy interests; and the Nicaraguan National Police was designated for serious human rights abuses. The rule simultaneously codified in the EAR that protection of human rights worldwide is an explicit basis for Entity List designations — a precedent-setting regulatory amendment extending the existing national-security and foreign-policy framework.

Switzerland's Federal Council amended the Ordinance on measures related to the situation in Ukraine (SR 946.231.176.72) to align with the remainder of the EU's tenth sanctions package, effective 8pm on 29 March 2023. The amendment extends the existing Russia import ban to additional petroleum products (including petroleum jelly and petroleum coke), bitumen/asphalt, bituminous mastics, carbon and synthetic rubber, adds further export controls and designations linked to drone transfers to Russia, and tightens reporting obligations in the financial sector.

Canada registered SOR/2023-46 on 2023-03-10, amending the Special Economic Measures (Russia) Regulations to add section 3.14 and a new Schedule 11. The section prohibits any person in Canada, and any Canadian outside Canada, from importing, purchasing or acquiring the listed steel and aluminum goods from Russia or from any person in Russia. Schedule 11 covers HS Chapter 72 (iron and steel), HS 7301-7306 (sheet piling, railway material, tubes, pipes and profiles) and aluminum products. Goods under a contract entered into before the regulations came into force are exempt; the regulations took effect on registration.

The Bureau of Industry and Security (BIS) added 37 entities under 38 entries to the Entity List, effective March 2, 2023, spanning six destinations: China (28), Pakistan (4), Burma (3), Russia (1), Belarus (1), and Taiwan (1). The China tranche — the largest — targets entities supporting the People's Liberation Army's military modernization, including BGI Research and Forensic Genomics International (genomic surveillance/data risk), Inspur Group Co. Ltd. (cloud servers supplied to Chinese military), and Loongson Technology (domestic CPU developer). Three Burmese entities, including the Ministry of Transport and Communications, are designated for providing surveillance equipment enabling the military junta's tracking and targeting of civilians. Pakistani entities Abdul Razaq Asim, Add-On Technology, and Dynamic Engineers are added for contributing to Pakistan's ballistic missile programs; Russian DMT Electronics and Belarusian DMT Trading LLC for export-control evasion. All listed entities are subject to a license requirement for all items subject to the EAR, with the review policy being presumption of denial for the majority of Chinese entries.

The Bureau of Industry and Security (BIS) added 76 Russian entities to the Entity List effective February 24, 2023, spanning three rationale categories: (1) biometric surveillance technology enabling Russian filtration operations in occupied Ukraine; (2) illicit acquisition of U.S.-origin controlled items; and (3) the Russian military-industrial complex encompassing missiles, aviation, shipbuilding, semiconductors, telecom, and defense electronics. All 76 entities are subject to a license requirement for all EAR-subject items with a presumption of denial; 66 entities receive footnote-3 designation as Russian military end-users, subjecting them to the Russia/Belarus Military End-User Foreign Direct Product Rule under §734.9(g). Four existing Entity List entries were simultaneously revised with additional aliases and tightened to a policy of denial. Notable designations include KAMAZ, the Skolkovo Foundation, Skoltech, Ilyushin Aviation Complex, and the State Missile Center Named After Akademika V.P. Makeyev.

The Bureau of Industry and Security (BIS) added 10 entities under 13 destination entries to the Entity List, effective February 24, 2023. The additions span three groups: (1) five Chinese entities operating in the commercial satellite and dual-use space sector — most notably Spacety Co., Ltd. and China HEAD Aerospace Technology Co., both suspected of supplying satellite imagery and space technology in support of the Russian military in Ukraine; (2) two Canadian procurement intermediaries (CPUNTO Inc. and Electronic Network Inc.) facilitating illicit acquisition of US-origin controlled items; and (3) three Russian defense-industrial procurement companies supplying the Russian military. All listed entities are subject to a license requirement for all EAR-subject items with a policy of denial, except EAR99 food and medicine which receive case-by-case review.

On 25 February 2023, one year into Russia's full-scale invasion of Ukraine, the Council of the European Union adopted Council Regulation (EU) 2023/427, the 10th package of sanctions, amending Regulation (EU) 833/2014. It entered into force on publication the following day (26 February 2023). The package bans imports of asphalt and synthetic rubber from Russia (with a temporary transitional import quota for rubber products running to 30 June 2024), expands the export ban on dual-use and advanced-technology goods, suspends further Russian media broadcasting licences in the EU, and designates 87 individuals and 34 entities — including Iranian persons and entities involved in drone manufacture and supply, and 96 entities tied to Russia's defence-industrial base — to the EU asset-freeze/travel-ban list.

On 24 February 2023, to mark the one-year anniversary of Russia's full-scale invasion of Ukraine, the UK government announced a new sanctions package including an import ban on over 140 goods (including iron and steel products processed in third countries), an export ban on battlefield-relevant goods, and 92 new asset-freeze designations. The measures were legislated by the Russia (Sanctions) (EU Exit) (Amendment) Regulations 2023 (SI 2023/440), which came into force on 21 April 2023, except the third-country-processed iron and steel import provision (Regulation 3), which came into force on 30 September 2023.

The Bureau of Industry and Security (BIS) established a new Iran Foreign Direct Product (FDP) rule and created Supplement No. 7 to Part 746 of the EAR, effective 24 February 2023, to address Iran's supply of UAVs to Russia for use against Ukraine. The rule adds twelve HTS-6 codes covering UAV-relevant components — aircraft engines, processors, capacitors, memories, and radio navigation equipment — many of which are EAR99 items outside existing ECCNs, requiring a new licence for exports and reexports to Iran. Simultaneously, the rule expands the existing Russia/Belarus FDP rule to cover these same items, closing a gap where foreign-produced items derived from US technology could transit to Russia via Iran without triggering EAR licence requirements.

The Bureau of Industry and Security expanded EAR sanctions against Russia and Belarus effective 24 February 2023, adding 322 HTS-6 industrial items to Supplement No. 4 to Part 746 (oil-and-gas equipment, flat-rolled steel, pumps, turbines, marine and aviation engines) and 276 luxury goods to Supplement No. 5. Supplement No. 6 was amended to add biological and chemical-synthesis equipment including bioreactors, peptide synthesizers, and nucleotide reagents, targeting Russia's biodefence and dual-use procurement pathway. The rule also migrated Supplement No. 2 from Schedule B to HTS-6 identifiers to align with allied partner frameworks, added Taiwan to the list of countries excluded from licence requirements, and extended Section 744.7 end-use restrictions to cover in-country transfers inside Russia and Belarus.