In response to Russia’s invasion of Ukraine, the United States has imposed significant restrictions on exports to Russia.  Effective February 24, 2022, goods covered by Categories 3-9 of the Commerce Control List (CCL) are subject to license requirements and licensing is under a “policy to deny.”  The involved CCL categories cover:  Electronics; Computers; Telecommunications; Information Security; Sensors and Lasers; Navigation and Avionics; Marine; and Aerospace and Propulsion.  These restrictions apply to exports, re-exports, and in-country transfers.  The new measures follow an Executive Order issued on February 21, 2022, which barred any transactions relating to two eastern regions of Ukraine (the so-called DNR and LNR regions).

The announced sanctions also restrict the export of nearly all goods to “military end users” or for “military end uses.”  Several dozen entities and individuals (both in Russia and in Belarus) have also been added to U.S. sanction lists.  Additionally, the U.S. Treasury Department is acting to prohibit Russia’s two largest banks (Sberbank and VTB Bank) from processing payments through the U.S. financial system.

The situation is quite fluid at the moment and it is possible that the scope of these sanctions will evolve.  Should you have any questions, please contact Joseph Spraragen ([email protected]) or any of our attorneys.