如果你是美国人.S. exporter wondering what the news of additional Export Administration Regulations (耳朵) export controls for 俄罗斯 means for you, 在这里 are the three key points you need to know:
- All goods, software, 和 technology described in Commerce Control List (创新领导力) Categories 3-9 (i.e. everything with an ECCN in these categories) now requires a license to 俄罗斯, with very limited license exception availability.
- Everything subject to the 耳朵, including 耳朵99 items, (except some food & 医学, ECCN 5A992/5D992 items) now requires a license if it is intended for a military end use (MEU) or a military end user in 俄罗斯.
- Many 俄罗斯n entities have been added to restricted parties lists this week. Others have been moved to more restrictive lists (especially to the Entity List).
Now that you know, what should you do?
- Re-screen all customers, distributors, etc. in 俄罗斯 against all restricted parties lists. Take action as needed.
- Hold all exports in Category 3-9 ECCNs. Reconfirm classifications 和 consider applying for licenses (underst和ing that the licensing policy is now generally denial).
- Hold everything else pending MEU review. If it clears review, proceed with caution. If not, you may seek a license.
- We recommend reading the whole 国际清算银行 rule, 在这里.
ECTI will continue to monitor changes to the 耳朵 or ITAR as it relates to the 俄罗斯-乌克兰 war. 访问 reex9.hataselektrik.com to learn about our company, our faculty, our staff 和 our esteemed Export Compliance Professional (ECoP®) certification program. 找到即将到来的 e-seminars, 现场研讨会 和 生活皇冠365官方app，以及 browse our catalog of 80-plus on-dem和 webinars, visit our ECTI Academy. You also can call the Export Compliance Training Institute at +1 (540)-433-3977 for more information.
斯科特Gearity is President of ECTI, Inc.
