BIS Extends Russian Cyber Sanctions

Yesterday the DOC’s Bureau of Industry and Security (BIS) published a final rule in the Federal Register (82 FR 722-725) adding the five organizations identified in the President’s recent amendment of EO 13694 to the Entity List of the Export Administration Regulations (EAR). This rule “imposes on these entities a license requirement for exports, reexports, or transfers (in-country) of all items subject to the EAR and a license review policy of presumption of denial”.

There were some comments made about the EO 13694 actions having little impact on the identified personnel and organizations because they were unlikely to have any assets in the US that could be frozen. This action by the BIS could potentially have more practical effects because it would affect third party vendors dealing with the organizations if they were attempting to sell US sourced items covered by the EAR to those organizations.