U.S. BIS makes changes to Russia and Belarus sanctions under Export Administration Regulations (EAR)

The final rule is effective on June 12, 2024.

The final rule is effective on June 12, 2024.

The Bureau of Industry and Security (BIS) of the U.S. Department of Commerce today released a final rule that makes changes to the Russia and Belarus sanctions under the Export Administration Regulations (EAR).

The final rule (104 pages):

  • Expands the scope of items identified under two EAR supplements that are subject to the EAR’s Russian and Belarusian industry sector sanctions by imposing a “software” license requirement for certain EAR99-designated “software” when destined to or within Russia or Belarus, and narrowing the scope of commodities and software that may be authorized for export, reexport, or transfer (in-country) to or within Russia or Belarus under license exception consumer communications devices (CCD)
  • Consolidates the EAR’s Russian and Belarus sanctions into a single section, while maintaining the existing related regulatory supplements identifying items that are subject to certain of those sanctions
  • Amends the EAR by adding five entities and eight addresses to the entity list under the destinations of China and Russia, which have been determined by the U.S. government to be acting contrary to the national security or foreign policy interests of the United States
  • Makes two additional revisions to the EAR (1) to confirm the criteria used when revising, suspending, or revoking EAR license exceptions; and (2) to clarify the control status of fasteners for purposes of the EAR’s Russian and Belarusian industry sector sanctions

The final rule is effective on June 12, 2024 (except for amendatory instruction 14, which is effective September 16, 2024).

Read a related BIS release (June 12, 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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