U.S. orders temporarily denying export privileges of three Russian airlines

Ongoing apparent violations of the comprehensive export controls imposed on Russia by the U.S. Department of Commerce

Three Russian airlines

The Bureau of Industry and Security (BIS) of the U.S. Department of Commerce today issued a release denying the export privileges of three Russian airlines due to ongoing apparent violations of the comprehensive export controls imposed on Russia by the U.S. Department of Commerce.  

According to the BIS release [PDF 124 KB], these three temporary denial orders (TDOs) terminate the right of these airlines to participate in any transactions subject to the Export Administration Regulations (EAR), including exports from the United States and reexports of U.S. items and technologies subject to the EAR from abroad.

Today’s TDOs are issued for 180 days and may be renewed.  


BIS in February 2022 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 on the Commerce Control List.   

BIS in March 2022 further 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 (AVS). Accordingly, any U.S.-origin aircraft or foreign aircraft that includes more than 25% controlled U.S.-origin content is subject to a license requirement if, for example, it is Russian-owned or operated and exported to Russia. 

KPMG observation

BIS previously issued an order temporarily denying export privileges of a Belarusian airline. Read TradeNewsFlash


For more information, 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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