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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

April 18, 2024

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
    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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