US Sectoral Sanctions
US Sectoral Sanctions - BIS (cont'd)
Export / Reexport Restrictions (cont'd)
BIS FAQ clarifications and license applications / actions (including re offshore drilling)
quite strict to date, like OFAC
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Some further important BIS actions
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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
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this sparked Russian gov't support development of local substitute (see report) – production kick-off
now anticipated for 2021
April-June 2020 publication of three final rules targeting national-security-controlled exports
and re-exports to Russia, China and Venezuela (see slides 12-13 above)'
Feb. 2020 final rule tightening some Country Group designations - affecting some exports
and reexports to Russia (based on missile, nuclear, and chemical & biological weapons
proliferation concerns)
And see BIS 2015 Guidance on Due Diligence to Prevent Unauthorized
Transshipment / Reexport of Controlled Items to Russia
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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
Morgan Lewis
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