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U.S. license exception for medical devices destined for Russia, Belarus, and certain regions of Ukraine

Final rule amending the Russia and Belarus sanctions under the Export Administration Regulations (EAR)

April 25, 2024

The Bureau of Industry and Security (BIS) of the U.S. Department of Commerce today released a final rule amending the Russia and Belarus sanctions under the Export Administration Regulations (EAR) to introduce a new license exception for EAR99 medical devices and related parts, components, accessories, and attachments for use in or with medical devices that are destined for Russia, Belarus, and certain regions of Ukraine (the Crimea region and covered regions).

This rule aims to authorize certain exports, reexports, and transfers (in-country) of “medical devices” that are regularly approved and that advance U.S. national security and foreign policy interests.

BIS estimates that the new medical devices license exception will result in a reduction of 3,900 license applications being submitted to BIS annually.

The rule also makes two corrections to the EAR, consisting of:

  • One correction to an end-user control under the EAR that was affected by a final rule published March 21, 2024 (read TradeNewsFlash)
  • A cross-reference correction to the final rule published January 25, 2024 (read TradeNewsFlash)

Read a related BIS release

    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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