US Sectoral Sanctions

What's Newest (cont'd) BIS (Commerce Dep't) - cont'd expansion of military end-use and end-user restrictions - further complicating US companies' business ܀ expands requirement to obtain specific licenses for export to military end users/uses in Russia (and China and Venezuela) covers wide range of potential dual-use items (there is already a blanket policy of denial for defense articles for these countries) adopts regional stability controls for certain exports to Russia; and adds a new reporting requirement for controlled items and see related new FAQS 1-32 re the subject changes to EAR section 744.21 And now-final rule eliminating re-export authorizations APR ܀ to remove a provision of License Exception Additional Permissive Re-exports ("APR") for a small group of countries incl. Russia namely, would eliminate some permissive re-exports of sensitive US items to Russia (and some other countries) based on approval by one of certain close ally countries - "due to variations in how the United States and its partners ... perceive the threat caused by the increasing integration of civilian and military technology development in countries of concern" March 2020 Entity List additions for Russia (see slide 29) Note also recent US gov't multi-pronged measures aimed against several PRC state companies perceived to be linked to the military - could have effects for Russian companies - - BIS 26 August 2020 designation of 24 PRC companies to its Entity List (ref. slide 28) US Defense Dep't 3 Dec. designation of newest fourth tranche of "Communist Chinese military companies" (with link there to the previous designations from earlier this year) And related new Executive Order 13959 of 12 Nov., banning transactions by US persons in publicly traded securities of entities identified as such (and our related lawflash here) Morgan Lewis 13

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