U.S. BIS expands license requirements for exports to Iran, Russia, Belarus, and Crimea region under the EAR

Additional controls now warranted under the Export Administration Regulations

Additional controls now warranted under the Export Administration Regulations

The Bureau of Industry and Security (BIS) of the U.S. Department of Commerce today released a final rule expanding the scope of items that require a license for export and reexport to Iran. The rule also expands the scope of the Russia/Belarus/Temporarily occupied Crimea region of Ukraine foreign direct product (FDP) rule and the Iran FDP rule.

Certain foreign-made items located outside the United States are subject to the Export Administration Regulations (EAR) if they meet criteria specified under one of the FDP rules under the EAR. The rule imposes a license requirement when these items are reexported or exported from abroad to Iran, Russia, Belarus, or the Temporarily occupied Crimea region of Ukraine.

Prior to this rule, BIS had not controlled all foreign transactions involving items covered by this rule, but in light of recent events and the need to fully leverage EAR controls to address U.S. national security and foreign policy interests, these additional controls are now warranted under the EAR.

The rule is effective today, April 18, 2024.

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

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