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.

On 21 December 2022 OFAC published final rule FR Doc 2022-27564, amending 30 CFR parts (31 CFR Parts 510, 525, 536, 539, 541, 542, 544, 546, 547, 548, 549, 551, 552, 555, 558, 560, 561, 562, 569, 576, 579, 582, 583, 584, 585, 591, 594, 596, 597, 598) to add or update general licenses authorising (1) official business of the US government and (2) official business of designated international organisations and entities across the full OFAC program library. The rule also updates the 50 Percent Rule interpretive provision, clarifying that an entity's property is blocked when one or more blocked persons own an aggregate interest of 50 percent or more — directly or indirectly — and corrects CFR citations to meet current Federal Register formatting requirements. Published as companion to FR Doc 2022-27639 (NGO and humanitarian GLs), both rules effective 21 December 2022.

OFAC published an interim final rule creating 31 CFR Part 599 to implement Executive Order 14059 (December 15, 2021), which declared a national emergency regarding the unusual and extraordinary threat posed by the global illicit drug trade, including fentanyl and synthetic opioid trafficking. The regulations establish blocking prohibitions, SDN List designation procedures, and enforcement mechanisms targeting foreign persons who materially contribute to international drug proliferation. OFAC stated it would supplement this interim rule with more comprehensive final regulations covering licensing, reporting, and penalty procedures.

On 20–21 December 2022 OFAC published two final rules (87 FR 78470 and 87 FR 78484) amending regulations across more than 30 sanctions programs to add general licenses (GLs) authorising four categories of humanitarian activity: (1) certain NGO transactions for disaster relief, health, democracy support, education, environmental protection, and peacebuilding; (2) provision of agricultural commodities, medicine, medical devices, replacement parts, and software updates for medical devices to blocked persons for personal, non-commercial use; (3) US government official-business transactions; and (4) official-business transactions of designated international organisations (e.g. UN, ICRC). The rules amended 29 CFR parts spanning Nicaragua, Iraq, Somalia, South Sudan, Yemen, and more than two dozen other sanctioned programs. The NGO GL excludes knowing fund transfers to blocked persons unless specified criteria are met, preserving the core blocking perimeter while lowering humanitarian-access friction.

The Bureau of Industry and Security added 36 entities — 35 in China, 1 in Japan — to the Entity List under a presumption of denial for all EAR-controlled items, effective December 16, 2022. The most consequential additions are Yangtze Memory Technologies (YMTC, simultaneously removed from the Unverified List), eight Cambricon AI-chip subsidiaries, and Shanghai Micro Electronics Equipment (SMEE), China's sole domestic lithography producer. Three existing entries were revised: CETC 13 and two affiliates gained a Footnote 3 Russian-military-end-user designation, bringing them under the Russia/Belarus Foreign Direct Product rule with a blanket denial policy.

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.

OFAC issued a determination under Executive Order 14071 (Russian Harmful Foreign Activities Sanctions) effective December 5, 2022, establishing a $60/barrel price cap on Russian seaborne crude oil. The measure prohibits US persons from providing six categories of covered services — trading/commodities brokering, financing, shipping, insurance (including reinsurance and P&I), flagging, and customs brokering — for the maritime transport of Russian crude oil unless the oil is purchased at or below $60/bbl. The determination was coordinated with the EU, G7 nations, and Australia as a unified coalition instrument designed to reduce Russian oil revenues while keeping global energy markets supplied. Three general licenses (GL 55, 56, 57) carved out limited exemptions for Japan's Sakhalin-2 imports, certain EU landlocked states, and vessel emergencies.

On 19 October 2022, the US Treasury's Office of Foreign Assets Control (OFAC) designated Russian national Yury Yuryevich Orekhov, resident in Dubai, UAE, under Executive Order 14024 for operating a network that procured military and sensitive dual-use technology from Western suppliers for Russian end-users. Two entities tied to Orekhov were designated alongside him: NDA Nord-Deutsche Industrieanlagenbau GmbH, based in Hamburg, Germany, and Opus Energy Trading LLC, based in Dubai, UAE. The designation blocks all US property and interests of the designated persons and generally prohibits US persons from transacting with them.

The US Bureau of Industry and Security imposed broad new controls on the export of advanced computing chips, chipmaking equipment, and US-person services supporting Chinese semiconductor fabrication. The October 7 2022 rule blocked supply of GPUs above set performance thresholds (initially 600 GB/s interconnect / 4800 TOPS) to China and added end-use restrictions on manufacturing tools used in advanced (≤14/16 nm logic, ≤18 nm DRAM, ≤128-layer NAND) facilities, with a foreign direct product rule extending coverage globally.

The Bureau of Industry and Security (BIS) Office of Antiboycott Compliance amended Supplement No. 2 to Part 766 of the Export Administration Regulations to update penalty determination guidance for administrative enforcement cases involving antiboycott violations. The rule recategorizes violations — Category A now contains only the most serious violations with penalties beginning at the statutory maximum — and eliminates "no admit/no deny" settlements, requiring all settlement agreements to include admissions of fact. The changes apply to all US persons subject to antiboycott provisions, principally those receiving or complying with requests tied to the Arab League boycott of Israel.

The Bureau of Industry and Security (BIS) added 31 Chinese entities — including Yangtze Memory Technologies Co., Ltd. (YMTC), China's largest NAND flash manufacturer — to the Unverified List (UVL), suspending license exceptions and requiring end-user statements for all EAR-controlled items destined to these parties. BIS simultaneously removed nine Chinese entities previously on the UVL after successfully completing end-use checks. The rule also established a new 60-day UVL-to-Entity-List escalation clock and clarified that sustained host-government obstruction of end-use checks constitutes independent grounds for Entity List designation — a structural enforcement change aimed at closing China's pattern of blocking BIS post-shipment verification visits.

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.

FinCEN issued a final rule (87 FR 59498, September 30, 2022) implementing the Corporate Transparency Act (CTA) by requiring most corporations, limited liability companies, and similar entities created in or registered to do business in the United States to file beneficial ownership information (BOI) reports with FinCEN. Reporting companies must identify two categories of individuals: beneficial owners (persons exercising substantial control or owning ≥25% of the entity) and company applicants (persons who filed the formation documents). Entities formed before January 1, 2024 had until January 1, 2025 to file; entities formed on or after that date had 30 days. Non-compliance carries civil penalties of up to $500/day and criminal penalties of up to $10,000 and two years imprisonment.

OFAC reissued the Central African Republic Sanctions Regulations (31 CFR Part 553) in their entirety on 29 September 2022, replacing the abbreviated framework first published on 7 July 2014 under Executive Order 13667. The reissuance adds interpretive guidance, definitions, and general licenses — including provisions for humanitarian assistance, personal communications, and non-commercial personal remittances — without expanding the underlying substantive sanctions perimeter. The action is primarily a regulatory codification that provides compliance clarity for financial institutions and other US persons transacting with or near CAR.

OFAC reissued the Western Balkans Stabilization Regulations (31 CFR Part 588) in their entirety on 29 September 2022, updating the framework that implements Executive Orders 13219 (2001), 13304 (2003), and 14033 (2021). The reissuance added three new definitions, expanded interpretive guidance, incorporated three new general licenses, and explicitly operationalised E.O. 14033's expanded emergency — which extended the Western Balkans sanctions perimeter to cover corruption and anti-democratic destabilisation, not just armed-conflict threats. The regulations apply to persons in or linked to the territory of the former Socialist Federal Republic of Yugoslavia and the Republic of Albania.

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 Bureau of Industry and Security (BIS) issued an interim final rule (IFR, 87 FR 55241, FR Doc. 2022-19415) amending the Export Administration Regulations (EAR) to authorize the release of specified items to all entities on the Entity List without a licence when such release occurs in the context of a "standards-related activity." The IFR expanded a narrower June 2020 predecessor that had applied only to Huawei and its affiliates; this 2022 rule extended equivalent authorization to the full Entity List. Authorized items include EAR99 technology and software, items controlled solely for anti-terrorism (AT) reasons, and certain cryptographic technology (ECCNs 5D002 and 5E002) used in standards development. The rule amended 15 CFR §§ 734.10, 744.11, 744.16, and Part 772 and was superseded by a broader 2024 IFR that recasted the carve-out as an activity-based exclusion from EAR jurisdiction entirely.

OFAC reissued the Cyber-Related Sanctions Regulations (31 CFR Part 578) in their entirety on 6 September 2022, replacing the abbreviated placeholder framework first published on 31 December 2015. The reissuance implements Executive Order 13694 (1 April 2015, blocking property of persons engaging in significant malicious cyber-enabled activities) and Executive Order 13757 (28 December 2016, expanding that authority to include election interference). The full-form regulations add interpretive definitions, general licences, and civil-penalties provisions — providing compliance clarity for US financial institutions and technology companies without expanding the underlying sanctions perimeter.

The US Department of Defense published a final rule (DFARS Case 2020-D007) in the Federal Register on 25 August 2022, effective the same day, amending the Defense Federal Acquisition Regulation Supplement to implement section 849 of the FY2020 National Defense Authorization Act. The rule prohibits DoD's acquisition of tantalum metals and alloys melted or produced in North Korea, China, Russia or Iran, and of any end item manufactured in one of those countries that contains such tantalum.

The U.S. Bureau of Industry and Security (BIS) added seven Chinese entities — under seven entries — to the Entity List, effective August 24, 2022, for acquiring or attempting to acquire U.S.-origin items in support of China's military modernization efforts. The entities span China's state-owned aerospace, space-technology, electronics, and control-systems research institutes. All seven entries carry a license requirement covering all items subject to the EAR, with a presumption-of-denial review policy.

The Inflation Reduction Act (Public Law 117-169), signed by President Biden on 16 August 2022, contains the largest single package of clean-energy and clean-manufacturing subsidies in US history — Congressional Budget Office scored the energy and climate provisions at $369B over 10 years, with subsequent Treasury / academic estimates reaching $800B-$1.2T as uptake exceeded baseline. Core mechanisms include the Section 30D Clean Vehicle credit ($7,500 per qualifying EV), the Section 45X Advanced Manufacturing Production Credit (per-unit credits for domestically-produced battery cells, modules, electrodes, and critical-mineral processing), the Section 48E Clean Electricity Investment Credit, and the Section 45V Clean Hydrogen Production Credit. Critically, the law contains Foreign Entity of Concern (FEOC) provisions barring credit eligibility for vehicles or components linked to entities controlled by China, Russia, Iran, or North Korea.

The Bureau of Industry and Security (BIS) amended the Commerce Control List (CCL) under the Export Administration Regulations (EAR) to implement four emerging and foundational technology decisions agreed at the December 2021 Wassenaar Arrangement Plenary meeting, pursuant to ECRA Section 1758. The rule adds new export controls on ultra-wide bandgap semiconductor substrates (gallium oxide Ga₂O₃ and diamond), ECAD software for Gate-All- Around Field-Effect Transistor (GAAFET) integrated circuit development, and Pressure Gain Combustion (PGC) technology for advanced gas turbine engines. Controls require a licence for items destined to countries listed in the NS:1 and AT:1 columns of the Commerce Country Chart; ECAD software controls (ECCN 3D006) have a delayed compliance date of October 14, 2022.

The CHIPS and Science Act (Public Law 117-167), signed into law by President Biden on 9 August 2022, appropriated $52.7 billion in direct semiconductor industry support: $39B in manufacturing incentives administered by the Commerce Department, $13.2B for R&D and workforce, and $0.5B for legacy-chip and supply-chain programs. It also created an Advanced Manufacturing Investment Credit (Section 48D) — a 25% refundable investment tax credit on qualified semiconductor manufacturing property. The law included a "guardrails" clause prohibiting recipients from expanding advanced-node capacity in countries of concern (most prominently China) for 10 years following award.

On 4 August 2022 OFAC formally published in the Federal Register nine general licenses (GLs 17–25) that had previously been made available only on OFAC's website under EO 14065 (Donetsk/Luhansk regions) and, for GL 25, also EO 13685 (Crimea). GL 17, which authorised wind-down of Donetsk/Luhansk transactions, had already expired on 23 March 2022. GLs 18–25 remain in force and authorise a structured set of humanitarian and civil-society carve-outs — covering agricultural commodities, medicine and medical devices, telecommunications, official international organisation business, personal remittances, internet-based communications, NGO activities, civil maritime services, and journalistic activities — within the otherwise restricted territory of Crimea, the so-called Donetsk People's Republic (DNR), and the Luhansk People's Republic (LNR).

On 13 July 2022 OFAC formally published in the Federal Register two general licenses (GL 2 and GL 10) that had been issued under the Ukraine-/Russia-Related Sanctions program and made available previously only on OFAC's website. Both licenses had already expired by the time of publication: GL 2 (EO 13662 Directive 4 wind-down, expired September 2014) authorised a limited window to wind down contracts involving Russian energy-sector entities subject to sectoral sanctions, while GL 10 (EO 13685 Crimea, expired October 2016) authorised divestiture of holdings in blocked Russian infrastructure entity PJSC Mostotrest. The Federal Register codification is an administrative archival step with no substantive change to the sanctions regime.

OFAC adopted a final rule on 1 July 2022 amending the Global Terrorism Sanctions Regulations (GTSR, 31 CFR Part 594) to implement Executive Order 13886 ("Modernizing Sanctions To Combat Terrorism," 9 September 2019). The rule expands the designation criteria in §594.201 to reflect EO 13886's additions, allowing OFAC to block property of foreign persons who act on behalf of, or provide material support to, foreign terrorist organizations (FTOs) — broadening the perimeter beyond EO 13224's original focus on persons threatening international peace and stability through terrorism. Supporting amendments update cross-references and the definition of "effective date" throughout Part 594 to reflect the new authority baseline.

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.

The Bureau of Industry and Security (BIS) published a final rule (FR Doc 2022-11761) on June 1, 2022 adding a new section (15 CFR § 743.6) to the Export Administration Regulations (EAR) requiring BIS to notify Congress before issuing export licenses for semiautomatic firearms (ECCN 0A501.a) where a single license application meets or exceeds $4 million in value. The notification requirement applies to destinations outside Country Groups A:5 and A:6 (close US allies) and does not apply to exports under License Exception GOV for US government or NATO agency use. The rule is a Biden-era oversight measure adopted under the Export Control Reform Act of 2018 (ECRA); it is a predecessor step in the regulatory arc that culminated in the 2024 BIS Firearms IFR (FR Doc 2024-08813), which was later partially rescinded in 2025.

On 27 May 2022 OFAC formally published in the Federal Register two general licenses (GL 13Q and GL 13R) that had been issued under the Ukraine-/Russia-Related Sanctions program and previously made available only on OFAC's website. Both licenses had already expired by the time of FR publication: GL 13Q (issued 24 Jan 2022, expired 27 Apr 2022) authorised the divestiture or transfer of debt, equity, or other holdings in GAZ Group to a non-US person; GL 13R (issued 25 Apr 2022, expired 25 May 2022) superseded GL 13Q and continued the wind-down authorisation for a further 30 days. The Federal Register publication is an administrative archival step with no substantive change to the active sanctions regime; both GLs were expired at time of codification.

On 27 May 2022 OFAC formally published in the Federal Register two general licenses (GL 15K and GL 15L) issued under the Ukraine-/Russia-Related Sanctions program. Both licenses had already expired by the time of Federal Register publication. GL 15K (effective 24 Jan 2022, expired 27 Apr 2022) authorised a broad set of manufacturing, sales, and operational transactions involving GAZ Group and its majority-owned subsidiaries; GL 15L (effective 25 Apr 2022, expired 25 May 2022) superseded GL 15K and narrowed authorisation to wind-down transactions only, while explicitly prohibiting new debits to GAZ Group accounts at US financial institutions. The FR publication is an administrative archival step codifying web-published licences after their operative windows had already closed.

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.

OFAC final rule (FR Doc 2022-12445, 87 FR 35068) amending the Cuban Assets Control Regulations at 31 CFR Part 515 to implement elements of the Biden administration's May 16, 2022 Cuba policy announcement supporting the Cuban people. The rule reinstates the group people-to-people educational travel general license (suspended under the Trump administration) for organizations sponsoring exchanges that promote meaningful contact with Cubans and support civil society; removes the $1,000 quarterly limit on family remittances to close relatives in Cuba; authorizes donative remittances to Cuban nationals not affiliated with the government or Communist Party; and expands authorizations for professional meetings and conferences in Cuba. Effective June 9, 2022.

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.

On 2 May 2022 OFAC published a comprehensive final rule in the Federal Register renaming the Ukraine Related Sanctions Regulations (31 CFR Part 589) to the Ukraine-/Russia-Related Sanctions Regulations and replacing the abbreviated regulatory text that had been in place since 2014 with a fully elaborated framework. The new Part 589 incorporates interpretive guidance, definitional provisions, and consolidated general licenses implementing Executive Orders 13660, 13661, and 13662 — the original March 2014 Ukraine/Crimea-crisis authorities. The rule does not introduce new substantive prohibitions; it formalises and makes accessible the regulatory infrastructure that underlies subsequent GL issuances (e.g., GL 13Q/13R, GL 15K/15L) and OFAC designation actions under the Ukraine-/Russia-Related Sanctions program.

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.

BIS published a technical correction to the Entity List (15 CFR Part 744, Supplement No. 4) fixing three errors in the February 14, 2022 final rule (87 FR 8180; FR Doc. 2022-03029) that added and revised Huawei entities. Two entries — Huawei Cloud Brazil (São Paulo) and Huawei Technologies Co., Ltd. (China, with 22+ affiliated addresses) — incorrectly cited §736.2(b)(3)(vi) as the Foreign Direct Product rule trigger instead of the correct §734.9(e) (the Huawei-specific FDP rule); a third error was a typographical fix to the footnote reference ("except for" → "EXCEPT\2\ for"). No new restrictions were created; the substantive export control status of all listed Huawei entities is unchanged, but exporters relying on the CFR text now have the correct regulatory citation for license requirement determinations.

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.

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.

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.

Effective 2 March 2022, the US Bureau of Industry and Security (BIS) extended to Belarus the same sweeping EAR sanctions imposed on Russia following Russia's full-scale invasion of Ukraine on 24 February 2022. The rule adds Commerce Control List (CCL)-based license requirements for Belarus with a policy of denial across virtually all categories, extends both the Russia Foreign Direct Product (FDP) rule and the Russia Military End User (MEU) FDP rule to cover Belarus and Belarusian military end users, and aligns Belarus with Russia's license review policy. The action was triggered by Belarus's active enablement of the Russian military operation from its territory.

On 1 March 2022, OFAC published an interim final rule adding the Russian Harmful Foreign Activities Sanctions Regulations (RuHSR) at 31 CFR Part 587, codifying into Title 31 of the Code of Federal Regulations all prohibitions previously imposed by Executive Order 14024 of 15 April 2021. The regulations were issued in abbreviated form to provide immediate public guidance, with OFAC indicating an intent to supplement them with additional definitions, general licenses, and interpretive guidance. All transactions prohibited under EO 14024 — including prior sectoral determinations and directives targeting Russia's financial services sector, sovereign debt markets, and key state institutions — are formally prohibited under Part 587, giving domestic courts and compliance teams a stable regulatory anchor.

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.