U.S. final rule imposing new export control measures on Iran

Addresses the use of Iranian unmanned aerial vehicles (UAVs) by Russia in its war against Ukraine

Addresses the use of Iranian unmanned aerial vehicles (UAVs) by Russia in its war against

The Bureau of Industry and Security (BIS) of the U.S. Commerce Department today released for publication in the Federal Register a final rule amending the Export Administrations Regulations (EAR) to impose new export control measures on Iran.

The final rule [PDF 293 KB]—effective today, February 24, 2023—addresses the use of Iranian unmanned aerial vehicles (UAVs) by Russia in its ongoing war against Ukraine.

The amendments to the EAR target Iran’s supply of UAVs to Russia and build on prior EAR amendments, including the addition of Iranian entities to the EAR entity list as Russian “military end users.” Specifically, these controls impose license requirements for a subset of EAR99 items that are destined to Iran, regardless of whether a U.S. person is involved in the transaction.

The final rule also:

  • Identifies certain foreign-produced items as subject to the EAR by adding a new foreign direct product (FDP) rule specific to Iran that applies to items in certain categories of the Commerce Control List (CCL) and the EAR99 items identified in this new supplement
  • Revises the EAR’s existing Russia/Belarus FDP rule to reference the EAR99 items
  • Impose license requirements on additional exports from abroad and reexports to Iran, Russia, and Belarus


For more information, contact a professional with KPMG 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
Principal
E: ivaysfeld@kpmg.com

Amie Ahanchian
Principal
E: aahanchian@kpmg.com

Christopher Young
Principal
E: christopheryoung@kpmg.com

Gisele Belotto
Principal
E: gbelotto@kpmg.com

George Zaharatos
Principal
E: gzaharatos@kpmg.com

Andy Doornaert
Managing Director
E: adoornaert@kpmg.com

Jessica Libby
Principal
E: jlibby@kpmg.com
John Anderson
Managing Director
E: johneanderson@kpmg.com
Jenna Leigh Glass
Managing Director
E: jennaleighglass@kpmg.com

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