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
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
John Anderson
Managing Director
E: johneanderson@kpmg.com
Jenna Leigh Glass
Managing Director
E: jennaleighglass@kpmg.com

The KPMG name and logo are trademarks used under license by the independent member firms of the KPMG global organization. KPMG International Limited is a private English company limited by guarantee and does not provide services to clients. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 3712, 1801 K Street NW, Washington, DC 20006.