Morgan Lewis US and Russia Sanctions Update
US Sectoral Sanctions - BIS (cont'd)
US Dep't of Justice announcement in Nov. 2020 of guilty plea agreement with
Russian company and its owner, for their part in conspiracy to evade BIS-
administered sanctions against Russia - attempted export of American-made turbine
for use in Russian Arctic offshore oil drilling (and see further background news here
and here)
Another notable important BIS action with regard to Russia
2019 reported opposition to a US company's export to affiliates of United Aircraft Corp.
(owned by Rostec) of high-tech composite material needed for new-generation Russian
passenger liner MS-21
and reported related US pressure on Japanese producer of same material; this sparked
Russian gov't support development of local substitute (see report) - reportedly now being
certified, production kick-off anticipated for 2022
See BIS 2015 Guidance on Due Diligence to Prevent Unauthorized Transshipment /
Reexport of Controlled Items to Russia
Expresses BIS concern "about efforts by front companies and other intermediaries who are
not the true final end users..."
Special focus on third-country freight forwarders and other dubious parties listed as an
export item's final destination
See also OFAC May 2020 Guidance to Address Illicit Shipping and Sanctions Evasion
Practices
Morgan Lewis
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