Morgan Lewis US and Russia Sanctions Update
US Sectoral Sanctions - BIS (cont'd)
Export / Reexport Restrictions (cont'd)
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And, as noted above, per a 2015 amendment, BIS added Gazprom's South Kirinsky field
(Sea of Okhotsk, part of Sakhalin-3 areas project, off Sakhalin Island) to the Entity List
regardless whether in deepwater portion or not (the field has both)
this special designation was likely based on some particular factors
more such fields might eventually be named too, as also noted above (but none yet)
BIS FAQ clarifications and license applications / actions (including re offshore drilling) -
quite strict to date, like OFAC
Also further 2015-20 Russia-related Entity List additions - adding many new Russian,
Crimean, European and other OFAC-named SDN companies to this List (see slide 40)
Mostly in the cyber and/or defense categories; some of which are already OFAC-designated
SDNS or may be indirect SSIS (as 50%-or-more owned by a directly designated SSI)
March 2020 additions - Avilon Ltd. and Technomar: "for acting on behalf of a listed
company in circumvention of licensing requirements by procuring U.S.-origin items for
Technopole Company", which was listed in 2016
These companies are thus subject to BIS license requirement for all items that are subject
to the Export Administration Regulations (EAR), with presumption of denial
See the current full BIS Entity List here
Morgan Lewis
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