U.S. order renewing temporary denial of export privileges of Russian airline

Evidence presented by BIS demonstrated that the Russian airline acted in violation of the EAR and the temporary denial order

Evidence presented by BIS demonstrated that Russian airline acted in violation of EAR

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

The order [PDF 276 KB] is effective immediately and will remain in effect for 180 days. (Note that the notice is dated October 19, 2022, and scheduled to be published in the Federal Register on October 20, 2022).


  • An order was signed on April 21, 2022, denying the Russian airline export privileges for a period of 180 days to prevent an imminent violation of the Export Administration Regulations (EAR).
  • The Office of Export Enforcement on September 13, 2022, submitted a written request for renewal of the temporary denial order issued on April 21, 2022. The written request was made more than 20 days before the temporary denial order’s scheduled expiration.
  • Evidence presented by BIS demonstrated that the Russian airline acted in violation of the EAR and the temporary denial order; that such violations have been significant, deliberate and covert; and that there is a likelihood of imminent violations.
  • Therefore, any successors or assigns, agents, or employees of the Russian airline may not participate in any way in any transaction involving any commodity, software or technology exported or to be exported from the United States that is subject to the EAR, or in any other activity subject to 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
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Andy Doornaert
Managing Director
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Jessica Libby
E: jlibby@kpmg.com


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