Industrial Policy & Trade Monitor· 2666 actions· ✨ 90 recent

The US Bureau of Industry and Security modified the existing Entity List entry for Private Military Company 'Wagner' (Russia) by adding Footnote 3, formally designating it as a Russian military end user under 15 CFR § 744.21. Two new aliases and one new Saint Petersburg address were also added, bringing total aliases to five. The existing policy of denial for all EAR-controlled items applies globally — to any export, reexport, or in-country transfer to Wagner wherever located worldwide — with a narrow case-by-case review carve-out for EAR99 food and medicine.

The US Bureau of Industry and Security (BIS) removed nine Russian persons from the Unverified List (UVL) and simultaneously added them to the Entity List after the Russian government failed to facilitate end-use checks for more than 60 days — the first application of BIS's October 2022 escalation policy. All nine entities are subject to a license requirement covering all items subject to the EAR, with a policy of denial and no license exceptions available. The list spans electronics traders, state maritime infrastructure, defense R&D, microelectronics, and industrial equipment manufacturers.

The Bureau of Industry and Security added 24 entities across 26 entries to the Entity List, effective December 8, 2022, covering Latvia, Pakistan, Russia, Singapore, Switzerland, and the United Arab Emirates. Three distinct enforcement clusters are addressed: Russian defense-electronics firms and their foreign affiliates supporting Russia's military-industrial base post-Ukraine invasion; Singapore-based front companies that supplied controlled items to PASNA, an Iran-based Specially Designated National; and Pakistani and Emirati entities engaged in unsafeguarded nuclear activities and ballistic-missile proliferation. One entity (Safe Technical Supply Co., LLC) was simultaneously removed from three entries covering Oman, Saudi Arabia, and the UAE.

The Bureau of Industry and Security added 57 entities under 57 entries to the Entity List, effective September 30, 2022, in direct response to Russia's ongoing invasion of Ukraine and its illegal annexation of Ukrainian regions. Of the 57 entities, 56 are listed under Russia and one (Subsidiary Sevastopol Naval Plant of Zvezdochka Shipyard) under the Crimea Region of Ukraine. The additions span aviation repair and overhaul facilities, aerospace R&D institutes, naval propulsion, ballistic-missile producers, advanced-materials and quantum science institutes, and the federal metrology agency; 50 of the 57 receive footnote 3 designations as Russian military end users, subjecting them to the Russia/Belarus-Military End User Foreign Direct Product Rule. All are added with a license review policy of denial for all EAR-subject items except food and medicine designated EAR99.

The Bureau of Industry and Security expanded EAR sanctions against Russia and Belarus effective 15 September 2022, adding new export-control categories covering quantum computing equipment and related technology (new licensing requirements under a near-total policy of denial), discrete chemicals and biologics including fentanyl precursors and CBW-related production equipment (new Supplement No. 6 to Part 746), and 57 EAR99 industrial items added to the industry-sector sanctions list (Supplement No. 4). Six entities were concurrently designated as Russian Military End Users (MEU), and MEU/MIEU licensing restrictions were extended worldwide (previously limited to six countries). The rule also extended the Foreign Direct Product Rule to additional categories of foreign-made items.

The U.S. Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) by adding 36 entities under 41 entries to the Entity List, effective June 28, 2022. The entities — located across China, Lithuania, Pakistan, Russia, Singapore, the UAE, the United Kingdom, Uzbekistan, and Vietnam — were designated for acting contrary to U.S. national security or foreign policy interests. Key grounds include support for China's military modernization and AI-enabled surveillance programs, Pakistan-based proliferation concerns, and supply-chain facilitation for Russia amid the Ukraine invasion. The rule also revised eleven existing entries (Belarus, China, Russia, Slovakia) and corrected one entry (Pakistan).

The Bureau of Industry and Security published a final rule on 6 June 2022 (effective 2 June 2022) consolidating corrections, clarifications, and substantive amendments to the series of EAR Russia/Belarus rules issued between February and May 2022. The most significant substantive change eliminates the EAR99 food and medicine carve-out for 146 footnote-3-designated military end-user entities already on the Entity List, subjecting all items subject to the EAR — including previously exempt food and medicine — to licensing requirements with a policy of denial for the FSB, SVR, and GRU. Additional provisions clarify luxury goods value thresholds, oil refinery sector controls, and civil telecommunications license review policy, and correct cross-references in the Foreign Direct Product Rules for Russia and Belarus.

The US Department of Commerce Bureau of Industry and Security (BIS) added 71 entities — 70 Russian and 1 Belarusian — to the Entity List, effective June 2, 2022, in direct response to Russia's further invasion of Ukraine on February 24, 2022. The entities were designated as military end users acquiring or attempting to acquire US-origin items in support of Russia's military, and are subject to a policy of denial for all items subject to the Export Administration Regulations (EAR). Sixty-six entities receive a "footnote 3" military end-user designation, while five face outright denial with no license exceptions available beyond humanitarian food and medicine.

BIS published a CFR correction to the Entity List (15 CFR Part 744, Supplement No. 4) fixing the entry for Kaliningradnefteprodukt OOO, a Russian petroleum products distributor based in Kaliningrad originally designated in February 2018 under Executive Order 13662 for operating in Russia's energy sector and being controlled by a sanctioned person. The correction updates the entity's name spelling and address details; the underlying license requirement (all EAR items for use in §746.5 Russian industry sector projects, presumption of denial) remains unchanged.

BIS finalized changes to the Export Administration Regulations (EAR) governing controls on cybersecurity items — primarily intrusion software, command-and-control platforms, and surveillance tools capable of disrupting or monitoring information systems without authorization. The final rule, effective May 26 2022, revises License Exception ACE (Authorized Cybersecurity Exports) originally established by an October 2021 interim rule and narrows end-user carve-outs for government end users in Country Group D:5 and A:6 destinations. Exports of affected ECCNs (4A005, 4D001, 4D004, 4E001, 5A001.j, 5B001, 5D001, 5E001) to Country Groups E:1 and E:2 remain prohibited; D:1 through D:5 government-end-user transactions require a license.

Canada amended the Special Economic Measures (Russia) Regulations via SOR/2022-102, registered 18 May 2022, adding Schedule 6 (luxury goods) and Schedule 7 (goods usable in weapons production/manufacturing) to the list of items prohibited for export to, and in Schedule 6's case also import from, Russia. Both schedules took effect 60 days after registration (17 July 2022). Schedule 6 covers luxury alcohol, tobacco, textiles, footwear, clothing, jewellery, kitchenware, art, and some machinery; Schedule 7 covers raw materials (including tungsten and aluminium), pumps, vehicle parts, construction equipment, watercraft, and medical/dental/surgical equipment. The regulation also added 14 individuals to the Schedule 1 asset-freeze list.

The U.S. Department of Commerce Bureau of Industry and Security (BIS) expanded export-control sanctions on Russian industry by adding 205 HTS codes (478 Schedule B numbers) to Supplement No. 4 to Part 746 of the EAR, imposing a license requirement — with a presumption of denial — for all exports, reexports, and transfers (in-country) to or within Russia of covered industrial goods. The targeted categories span wood products, boilers, industrial machinery, pumps, compressors, textile and grinding equipment, and hydraulic motors, aligning U.S. controls with EU partner lists. The rule took retroactive effect May 9, 2022, two days before Federal Register publication on May 11, 2022.

At the Executive Branch's request, the US Nuclear Regulatory Commission issued an order suspending the general license authority in 10 CFR 110.21-110.24 for exports of source material, special nuclear material, byproduct material, and deuterium for nuclear end use to the Russian Federation, effective immediately on issuance (May 12, 2022) and published in the Federal Register on May 17, 2022. Exporters must now apply for a specific license under 10 CFR 110.31 for any such export to Russia, which the NRC evaluates case by case. The order followed the Executive Branch's determination that continued general-license exports to Russia were inimical to US common defense and security in the wake of the invasion of Ukraine.

The Bureau of Industry and Security (BIS) issued a final rule expanding license requirements under the EAR for all items on the Commerce Control List (CCL) destined for Russia and Belarus, retroactively effective April 8, 2022. The rule also removes certain license exceptions that previously allowed aircraft-related transactions involving Belarus to proceed without authorization. Issued in direct response to Russia's continued aggression in Ukraine and Belarus's role in enabling it, this measure substantially tightens the multilateral export- control perimeter first established by BIS in late February 2022.

BIS amended the Export Administration Regulations to add Iceland, Liechtenstein, Norway, and Switzerland to the list of countries excluded from certain EAR license requirements that apply to items destined for Russia or Belarus. The exclusion recognizes that these four countries have implemented substantially similar export-control regimes aligned with US restrictions, and applies specifically to the Foreign Direct Product (FDP) rule under EAR Part 734.9. The change reduces the licensing burden for entities in these partner countries when producing or handling items using US-origin technology or equipment in transactions with Russia/Belarus, consistent with the broader allied coordination approach adopted after February 2022.

The Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) by adding 120 entities under 120 entries to the Entity List, effective 1 April 2022 and published in the Federal Register on 7 April 2022. All 120 entities — located in Russia and Belarus — were determined to be acting contrary to US national security or foreign policy interests in the context of Russia's further invasion of Ukraine beginning 24 February 2022. The rule imposes a presumption-of-denial policy for all EAR-subject items and prohibits all license exceptions for exports, reexports, or in-country transfers to the listed parties. Ninety-five of the 120 entities are additionally designated under Footnote 3 of the Entity List as military end users, triggering the Russian/Belarusian Military End User foreign-produced direct product rule (MEU FDP Rule), extending US extraterritorial reach to non-US items made with US-origin technology.

On 4 April 2022 Australia's Minister for Foreign Affairs registered the Autonomous Sanctions (Export Sanctioned Goods—Russia) Amendment (No.1) Designation 2022, made under the Autonomous Sanctions Regulations 2011. It amended the existing Export Sanctioned Goods—Russia designation to add further categories of goods to the list of items whose export, supply or transfer to Russia is prohibited, extending an export-ban regime introduced in response to Russia's invasion of Ukraine. It took effect on registration.

Canada amended the Special Economic Measures (Russia) Regulations via SOR/2022-067, registered and in force 24 March 2022, establishing a new "Restricted Goods and Technologies List" and prohibiting any person in Canada, and any Canadian outside Canada, from exporting, selling, supplying or shipping any listed good or technology to Russia or to any person in Russia. The list is maintained and published separately by Global Affairs Canada and covers items with dual civilian/military applications across electronics, computers, telecommunications, sensors and lasers, navigation and avionics, marine, aerospace and transportation equipment.

Australia designated aluminium ores (including bauxite), alumina and aluminium hydroxide as "export sanctioned goods" for Russia under the Autonomous Sanctions (Export Sanctioned Goods -- Russia) Designation 2022, banning their export from Australia to Russia effective 20 March 2022. Prime Minister Scott Morrison announced the measure a day earlier as part of Australia's response to the invasion of Ukraine, framing it as an attack on Russia's aluminium industry, which sourced roughly 20% of its alumina from Australian supply. Rusal, Russia's dominant aluminium producer, was identified as the primary target.

The Bureau of Industry and Security created Supplement No. 5 to 15 CFR Part 746, establishing a new licensing requirement for the export, reexport, or in-country transfer of luxury goods to Russia, Belarus, and to Russian or Belarusian oligarchs and malign actors anywhere in the world, effective 11 March 2022. Covered goods span over 570 HTS-6 line items across categories including spirits and tobacco (above de minimis thresholds), clothing and leather goods (>$1,000 per item), jewelry and precious gemstones, watches (>$100), vehicles (>$25,000), seafood/caviar (>$100), art and antiques, and recreational vessels. The rule targets both bulk commercial exports to Russia and Belarus and personal luxury procurement by designated oligarchs worldwide, with a policy of denial for all such licence applications.

The UK government announced on 15 March 2022 that it would ban the export of high-end luxury goods to Russia in response to the invasion of Ukraine. The measure was implemented via new regulation 46B of the Russia (Sanctions) (EU Exit) Regulations 2019, inserted by the Russia (Sanctions) (EU Exit) (Amendment) (No. 8) Regulations 2022 (SI 2022/452), which was made on 13 April 2022 and came into force at 5pm on 14 April 2022. Regulation 46B prohibits the export, supply, or making available of luxury goods to, or for use in, Russia, covering goods with a sales price over £250 (excluding VAT) and vehicles over £42,000, spanning high-end fashion, works of art, jewellery, and vehicles, subject to licensing exceptions in Part 7.

BIS amended the Export Administration Regulations (EAR) to add the Republic of Korea (South Korea) to Supplement No. 3 to Part 746 — the list of partner countries excluded from certain license requirements under § 746.8 that apply to items destined for Russia or Belarus. South Korea received a "Full" designation, meaning it is fully exempt from the Russia/Belarus Foreign Direct Product (FDP) rule license requirements provided it maintains substantially similar export controls on Russia and Belarus under its own laws. The rule was effective March 4, 2022, six days before its publication in the Federal Register (87 FR 13627).

The Department of Commerce Bureau of Industry and Security (BIS) added 91 entities (across 96 entries) to the Entity List under 15 CFR Part 744, in direct response to Russia's further invasion of Ukraine on 24 February 2022. The listed entities span ten destinations — Belize, Estonia, Kazakhstan, Latvia, Malta, Russia, Singapore, Slovakia, Spain, and the United Kingdom — and include Russian military research institutes, shipbuilding facilities, aerospace and electronics manufacturers, and suspected front companies in third countries used to circumvent EAR controls. A license is required for all items subject to the EAR; the review policy is denial for 86 entities and case-by-case (for US Government-supported space programs) for five.

Effective 3 March 2022 (retroactive to five days before Federal Register publication), the US Bureau of Industry and Security (BIS) expanded Russian Industry Sector Sanctions under the Export Administration Regulations (EAR) by adding a new license requirement and denial policy for oil refinery equipment destined for or within Russia. The rule creates 15 CFR § 746.5(a)(1)(ii) and a new Supplement No. 4 to Part 746 enumerating approximately 20 categories of refining equipment — from crude distillation units and catalytic crackers to hydrocracking reactors and sulphur recovery units. Applications are subject to a policy of denial, with a narrow health-and-safety exception reviewed case by case. The stated rationale is to limit Russia's ability to generate oil-derived government revenues used to finance its military operations in Ukraine.

On 28 February 2022, South Korea's government condemned Russia's invasion of Ukraine and announced it would strengthen export control review to block strategic items -- microelectronics, telecommunications equipment, sensors, navigation equipment, avionics, marine equipment, and aircraft components -- from reaching Russia. The statement also committed Korea to joining the exclusion of designated Russian banks from the SWIFT international payments system, with implementation details to follow through interagency consultation, alongside plans to release strategic petroleum reserves and divert LNG cargoes to Europe.

On 25 February 2022, the day after Russia's full-scale invasion of Ukraine, the Council of the European Union adopted Regulation (EU) 2022/328, amending Regulation (EU) No 833/2014. It prohibits the sale, supply, transfer or export of dual-use goods and technology to any person, entity or body in Russia, or for military use or military end-users there, and extends to goods and technology suited for use in the oil refining industry and for the aviation and space industry, alongside a ban on related technical assistance, brokering, financing and insurance/maintenance services. The Regulation entered into force on the day after its Official Journal publication (OJ L 49, 25.2.2022), i.e. 26 February 2022.

Effective 24 February 2022 — the date of Russia's full-scale invasion of Ukraine — the US Bureau of Industry and Security (BIS) published an interim final rule (87 FR 12226, FR Doc 2022-04300) adding sweeping new export license requirements under a new § 746.8 of the Export Administration Regulations (EAR). The rule requires a licence for any item in CCL Categories 3–9 (electronics, computers, telecommunications, sensors, lasers, navigation/avionics, marine, aerospace, propulsion) exported, reexported, or transferred to Russia, with a review policy of denial. Two new Russia-specific Foreign Direct Product (FDP) rules extend US jurisdiction to foreign-manufactured goods: the Russia FDP Rule (§ 734.9(f)) covers all foreign-made items using US technology/equipment destined for Russia, and the Russia-MEU FDP Rule (§ 734.9(g)) covers items destined to 47 designated military-end-user (MEU) entities with no licence exceptions available. All three restrictions carry a presumption of denial, making this the most sweeping peacetime expansion of the EAR since its modern codification.