U.S. order temporarily denying export privileges of Russian airline

The order temporarily denying export privileges will remain in effect for 180 days.

Russian airline

The Bureau of Industry and Security (BIS) of the U.S. Department of Commerce today released for publication in the Federal Register an order temporarily denying export privileges of a Russian airline.

The order temporarily denying export privileges [PDF 277 KB] is effective immediately and will remain in effect for 180 days. (Note that the notice is dated May 20, 2022, and scheduled to be published in the Federal Register on May 25, 2022).


According to today’s notice:

  • The U.S. Commerce Department, through BIS, responded to Russia’s further invasion of Ukraine by implementing stringent export controls that primarily target Russia’s defense, aerospace, and maritime sectors.
  • Effective February 24, 2022, BIS imposed expansive controls on aviation-related items to Russia, including a license requirement for the export, reexport or transfer (in-country) to Russia of any aircraft or aircraft parts specified in Export Control Classification Number (ECCN) 9A991.
  • Effective March 2, 2022, BIS excluded any aircraft registered in, owned, or controlled by, or under charter or lease by Russia or a national of Russia from being eligible for license exception aircraft, vessels, and spacecraft. Accordingly, any U.S.-origin aircraft or foreign aircraft that includes more than 25% controlled U.S.-origin content, and that is registered in, owned, or controlled by, or under charter or lease by Russia or a national of Russia, is subject to a license requirement before it can travel to Russia.
  • The Office of Export Enforcement’s request to deny export privileges is based upon facts indicating that the Russian airline engaged in prohibited conduct by operating aircraft subject to the Export Administration Regulations (EAR) and classified under ECCN 9A991 on flights into Russia after March 2, 2022, without the required BIS authorization.
  • No BIS authorizations were either sought or obtained by the Russian airline for exports or reexports to Russia.
  • Based on this information, there are heightened concerns of future violations of the EAR.

For more information on sanctions and other responses to Russia’s war on Ukraine, visit KPMG’s dedicated website.

Contact a professional with KPMG’s Trade & Customs services:

Doug Zuvich
Partner and Global Practice Leader
E: dzuvich@kpmg.com

John L. McLoughlin
Principal and East Coast Leader
E: jlmcloughlin@kpmg.com

Andy Siciliano
Partner and National Practice Leader
E: asiciliano@kpmg.com

Steve Brotherton
Principal and Global Export and Sanctions Leader
E: sbrotherton@kpmg.com

Luis (Lou) Abad
Principal, Washington National Tax
E: labad@kpmg.com

Irina Vaysfeld
E: ivaysfeld@kpmg.com

Amie Ahanchian
E: aahanchian@kpmg.com

Christopher Young
E: christopheryoung@kpmg.com

Gisele Belotto
E: gbelotto@kpmg.com

George Zaharatos
E: gzaharatos@kpmg.com

Andy Doornaert
Managing Director
E: adoornaert@kpmg.com

Jessica Libby
E: jlibby@kpmg.com

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