Morgan Lewis US and Russia Sanctions Update
US Sectoral Sanctions – BIS
Export / Reexport Restrictions
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The basic-limited August 2014 initial BIS Russia sanctions / license requirements
applying to any Russian end-users/uses
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When the exporter knows the items will be used directly or indirectly in exploration for or
production of oil or gas in Russian deepwater, Arctic offshore, or shale formations
Or is unable to determine whether the item will be used in such projects
And presumption of denial when for use in such projects "that have the potential to
produce oil" (here again, grey area where could produce both gas and oil)
And importantly, as noted above, BIS considers that condensate
This August 2014 regulation restricts (requires license for):
= oil
Only specifically designated ECCN items and also several listed types of drill pipe, casings,
wireline, downhole equipment (per Supp. No. 2 to Part 746.5 of the EAR)
for all Russian entities
when used in Russian deepwater, Arctic offshore, or shale projects
Expressly including, but not limited to
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drilling rigs
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parts for horizontal drilling
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drilling and completion equipment
subsea processing equipment
Arctic-capable marine equipment
wireline & down-hole equipment
Morgan Lewis
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drill pipe and casing
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software for hydraulic fracturing
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seismic acquisition equipment
high pressure pumps
• remotely operated vehicles
compressors, expanders, valves, risers
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