Pillsbury Winthrop Shaw Pittman

US and UK take modest steps to restrict exports to Russia

By Christopher R Wall, Stephan E Becker, Nancy A Fischer, Aaron R Hutman and Stephanie J Rohrer

The Obama administration has threatened to impose additional sanctions on Russia in response to the Ukraine crisis but so far has only blocked the assets of 32 individuals and one bank. Additionally, with little fanfare, the two primary US agencies responsible for issuing export licences announced that they have stopped processing applications for licences to export or re-export products and technology to Russia. The UK is suspending existing licences and will not process licence applications to export to Russia products and services that are destined for military use in the Ukraine.

The Commerce Department’s Bureau of Industry and Security (BIS) administers the Export Administration Regulations (EAR), which apply to exports of commercial and dual-use products, software and technology. BIS posted a notice on its website on 26 March stating that it has not been issuing licences for the export or re-export of items to Russia since 1 March, just days after the initial armed invasion of Crimea. During fiscal year 2013, BIS approved 1,832 licence applications for export/re-export to Russia of US origin items.

The State Department’s Directorate of Defense Trade Controls (DDTC) administers the International Traffic in Arms Regulations, which govern exports of military equipment, software, technology and services. DDTC posted a notice on its website on 27 March similarly announcing that it has placed a hold on issuing licences for exports to Russia…

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