US Issues More Russia Sanctions, Adds to Entity List
The U.S. last week announced a host of new sanctions and export controls against Russia, targeting Russian defense and technology companies, Russian government officials and various suppliers for supporting the country's military. The measures include hundreds of new designations and 57 additions to the Entity List, most of which will be subject to certain foreign direct product rule restrictions.
Sign up for a free preview to unlock the rest of this article
Timely, relevant coverage of court proceedings and agency rulings involving tariffs, classification, valuation, origin and antidumping and countervailing duties. Each day, Trade Law Daily subscribers receive a daily headline email, in-depth PDF edition and access to all relevant documents via our trade law source document library and website.
The new entity listings, which took effect Sept. 30, target parties that have sought to supply Russia’s military with controlled U.S. items or are involved in developing quantum computing technologies for Russia, the Bureau of Industry and Security said. They include 56 entities located in Russia and one entity in the Crimea region of Ukraine, where they operate as research and science institutions, aviation repair firms and technology companies.
The entities will be subject to a license review policy of denial for all items subject to the Export Administration Regulations, and some will be subject to a case-by-case license review policy only for food and medicine designated as EAR99. Fifty of the 57 entities will be subject to BIS’s Russia/Belarus Military End User Foreign Direct Product Rule, which will limit their ability to acquire certain foreign-produced goods made by or with U.S.-origin items.
Alongside BIS’s announcement, the Treasury and State departments added more than 250 entries to the Office of Foreign Asset Control’s Specially Designated Nationals List, which includes international suppliers, Russian officials and their family members, Russian technology and defense firms, government bodies, politicians and others for supporting the war in Ukraine. Also sanctioned were Elvira Sakhipzadovna Nabiullina, the country’s top central banker, for overseeing efforts to protect the Kremlin from Western sanctions, and Aleksandr Valentinovich Novak, a deputy prime minister, OFAC said.
The sanctions were designed to target “key leaders in Russia’s financial architecture as part of our aggressive and coordinated effort to hold Putin and his enablers accountable for his unprovoked invasion, and limit their ability to prop up their economy,” Treasury Secretary Janet Yellen said. “The Treasury Department, U.S. government, and our allies will not hesitate to take swift and severe actions against individuals and companies inside and outside of Russia who are complicit in this war.”
Both OFAC and BIS published new guidance to clarify how their sanctions and export restrictions affect non-U.S. people or other third countries that support Russia or Belarus. OFAC said non-U.S. people face sanctions risks for supporting Russia’s annexation of regions of Ukraine, including those who provide “material assistance, sponsorship, financial, material, or technological support for … sanctioned persons or sanctionable activity.” OFAC said it’s specifically focused on entities and people outside of Russia that provide the country with “political or economic” support.
But the agency stressed that its sanctions don’t block sales or transportation of Russian oil, petroleum and other fuels outside of the U.S. import ban. “OFAC will generally not impose sanctions on non-U.S. persons that engage in transactions that would be authorized for U.S. persons,” the agency said.
In its guidance, BIS said it’s “prepared to aggressively apply export controls” against any entity or person that tries to “provide material support for Russia and Belarus’s military and industrial sectors,” including efforts to “backfill” technologies and other items subject to U.S. and multilateral export restrictions. The guidance also outlines how BIS’s controls apply to entities subject to its Russia and Belarus foreign direct product rules. BIS Undersecretary Alan Estevez said the agency is “further clamping down on entities that are seeking to support Russia’s military effort,” both “inside and outside” of Russia.
All exports that now require a license as a result of the Entity List changes that were aboard a carrier to a port as of Sept. 30 may proceed to their destinations under the previous eligibility, BIS said.
The 57 new entities are:
Crimea Region of Ukraine
- Subsidiary Sevastopol Naval Plant of Zvezdochka Shipyard
Russia
- A. Lyulki Experimental-Design Bureau
- A. Lyulki Science and Technology Center
- AO Aviaagregat
- Central Aerohydrodynamic Institute
- Closed Joint Stock Company Turborus
- Federal Autonomous Institution Central Institute of Engine-Building N.A. P.I. Baranov
- Federal State Budgetary Institution of Science P.I. K.A. Valiev RAS of the Ministry of Science and Higher Education of Russia
- Federal State Budgetary Institution National Research Center Institute n.a. N.E. Zhukovsky
- Federal State Unitary Enterprise All-Russian Research Institute of Physical, Technical and Radio Engineering Measurements
- Federal State Unitary Enterprise State Scientific-Research Institute for Aviation Systems
- Federal Technical Regulation and Metrology Agency
- Institute of Physics Named After P.N. Lebedev of the Russian Academy of Sciences
- Institute of Solid-State Physics of the Russian Academy of Sciences
- Joint Stock Company 121 Aviation Repair Plant
- Joint Stock Company 123 Aviation Repair Plant
- Joint Stock Company 218 Aviation Repair Plant
- Joint Stock Company 360 Aviation Repair Plant
- Joint Stock Company 514 Aviation Repair Plant
- Joint Stock Company 766 UPTK
- Joint Stock Company Aramil Aviation Repair Plant
- Joint Stock Company Aviaremont
- Joint Stock Company Flight Research Institute N.A. M.M. Gromov
- Joint Stock Company Metallist Samara
- Joint Stock Company Moscow Machinebuilding Enterprise named after V. V.Chernyshev
- Joint Stock Company NII Steel
- Joint Stock Company Remdizel
- Joint Stock Company Special Industrial and Technical Base Zvezdochka
- Joint Stock Company STAR
- Joint Stock Company Votkinsk Machine Building Plant
- Joint Stock Company Yaroslavl Radio Factory
- Joint Stock Company Zlatoustovsky Machine Building Plant
- Limited Liability Company Center for Specialized Production OSK Propulsion
- Lytkarino Machine-Building Plant
- Moscow Aviation Institute
- Moscow Institute of Thermal Technology
- National Research Center Kurchatov Institute
- Omsk Motor-Manufacturing Design Bureau
- Open Joint Stock Company 20 Aviation Repair Plant
- Open Joint Stock Company 32 Repair Plant of Flight Support Equipment
- Open Joint Stock Company 170 Flight Support Equipment Repair Plant
- Open Joint Stock Company 275 Aviation Repair Plant
- Open Joint Stock Company 308 Aviation Repair Plant
- Open Joint Stock Company 322 Aviation Repair Plant
- Open Joint Stock Company 325 Aviation Repair Plant
- Open Joint Stock Company 680 Aircraft Repair Plant
- Open Joint Stock Company 720 Special Flight Support Equipment Repair Plant
- Open Joint Stock Company Volgograd Radio-Technical Equipment Plant
- Public Joint Stock Company Agregat
- Russian Institute of Radio Navigation and Time
- Rzhanov Institute of Semiconductor Physics, Siberian Branch of Russian Academy of Sciences
- Salute Gas Turbine Research and Production Center
- Scientific-Production Association Vint of Zvezdochka Shipyard
- Scientific Research Institute of Applied Acoustics
- Siberian Scientific-Research Institute of Aviation N.A. S.A. Chaplygin
- Software Research Institute
- Tula Arms Plant.