Morgan Lewis US and Russia Sanctions Update
CBW Act Sanctions (cont'd)
And some of the waivers to restrictions on arms sales and commerce NS-sensitive items
that were supplemented in connection with the first round CBW Act sanctions in August
2018 will continue, including:
items eligible for some standard license exceptions (need to carefully check the details) - i.e., no
license application needed
safety-of-flight items (for civil passenger aviation) - case-by-case licensing still OK
"deemed exports/reexports" to Russian nationals in the US – licensing permitted on case-by-case
basis unless otherwise prohibited
to wholly-owned US (and other foreign-company) subsidiaries in Russia
in support of government space cooperation - on same basis
on same basis
for state-owned/-funded enterprises - case-by-case licensing, but presumption of denial (not clear)
But other export-related waivers from 2018 are now removed, including
items that were subject to some other standard license exceptions (again, need to carefully check
the details)
for export/reexport of NS items to commercial end-users in Russia for civil end-uses (such
applications will now be reviewed under "presumption of denial")
for exports of US Munitions List items and NS items in support of commercial space flight activities
are to be removed following a six-month transition period (after which, subject to presumption of
denial)
Morgan Lewis
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