The U.S. Department of State’s Directorate of Defense Trade Controls (DDTC) and the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) both confirmed this week that they have suspended the issuance of licenses for controlled exports destined for Russia. The DDTC and BIS also announced that they would be continuing this practice until further notice. BIS, however, clarified that existing licenses will not be affected by its policy, only applications that were not granted by March 1, 2014.
The United Kingdom (UK) has also suspended licenses for exports of military and dual-use items destined for Russia. In contrast to BIS though, its suspension affects existing licenses and applications. In addition, the UK has suspended licenses for exports of items to third parties where the end-use of the item will be incorporation into equipment destined for Russia.
These suspensions of licenses by the DDTC, BIS, and the UK complement the growing sanctions list against various individuals involved in the annexation of Crimea. Both the European Union and the U.S. have warned Russia that they will not hesitate to impose additional sanctions if Russia further escalates the situation with Ukraine.
For more information on how your company may be affected by increasing restrictions on trade with Russia or on the sanctions or licenses regulations in general, please contact Joan Koenig, Mollie Sitkowski or any other member of Drinker Biddle’s Customs and International Trade team.