The OverRuled: BIS Export Controls Module has been updated with the following actions:
- 23 Sep 2023 - Azur Air - Denial Order; No monetary penalty
On September 26, 2023, BIS renewed against Azur Air ("Respondent") a Temporary Denial Order (TDO) issued on April 7, 2022, (87 Fed. Reg. 21614) for a period of 1 year in relation to violations of the Export Administration Regulations ("Regulations"). Specifically, the Respondent was involved in exporting or reexporting 9A991.b aircraft, among many others, on flights into multiple countries after March 2, 2022, without the required BIS authorization. Moreover, the continued operation of these aircraft by the Respondent, even on domestic routes within Russia and the company’s on-going need to acquire replacement parts and components, many of which are U.S.-origin, presents a high likelihood of imminent violations warranting imposition of a TDO.
- 23 Sep 2023 - UTair Aviation JSC - Denial Order; No monetary penalty
On September 23, 2023, BIS issued against UTair Aviation JSC ("Respondent") a Temporary Denial Order (TDO) for a period of 1 year in relation to violations of the Export Administration Regulations ("Regulations"). Specifically, the Respondent was involved in exporting or reexporting 9A991.b aircraft, among many others, on flights into Russia after March 2, 2022, without the required BIS authorization. Moreover, the continued operation of these aircraft by the Respondent, even on domestic routes within Russia and the company’s on-going need to acquire replacement parts and components, many of which are U.S.-origin, presents a high likelihood of imminent violations warranting imposition of a TDO. BIS further find that such apparent violations have been significant and deliberate. Therefore, issuance of the TDO is necessary in the public interest to prevent imminent violation of the Regulations and to give notice to companies and individuals in the United States and abroad that they should avoid dealing with the Respondent, in connection with export and reexport transactions involving items subject to the Regulations and in connection with any other activity subject to the Regulations.
- 23 Sep 2023 - PJSC Aeroflot - Denial Order; No monetary penalty
On September 23, 2023, BIS renewed against PJSC Aeroflot ("Respondent") a Temporary Denial Order (TDO) issued on April 7, 2022 (87 Fed. Reg. 21611) for a period of 1 year in relation to violations of the Export Administration Regulations ("Regulations"). Specifically, the Respondent was involved in exporting or reexporting 9A991.b aircraft, among many others, on flights into multiple destinations after March 2, 2022, without the required BIS authorization. Moreover, the continued operation of these aircraft by the Respondent, even on domestic routes within Russia and the company’s on-going need to acquire replacement parts and components, many of which are U.S.-origin, presents a high likelihood of imminent violations warranting imposition of a Temporary Denial Order ("TDO").
The OverRuled: Russia Trade Controls Resource Center has been updated with the following actions:
- 27 Sep 2023 (Russia - Countermeasures):
A total of 23 UK nationals are added to the Russian list of "personally sanctioned" individuals.
- 26 Sep 2023 (Russia - Countermeasures):
The Russian Central Bank extends restrictions for non-Russian residents of "unfriendly" states regarding the transfer of money outside of Russia from their broker and trust management accounts opened in Russia.
- 23 Sep 2023 (BIS):
BIS again renewed three Temporary Denial Orders ("TDOs") for three Russian aviation companies: Azur Air, UTair Aviation JSC, and PJSC Aeroflot. Unlike previous TDO renewals for these airlines, these latest renewals extend the TDO for each airline for a period of one year instead of 180 days.
- 15 Sep 2023 (Switzerland):
Switzerland issues updated guidance for its measures against Russia.
The OverRuled: China Trade Controls Resource Center has been updated with the following actions:
- 25 Sep 2023 (BIS):
BIS added 28 entities to the Entity List, including 11 under destination of the PRC for the following reasons:
- Being implicated in a conspiracy to violate U.S. export controls;
- Having procured and/or attempted to procure U.S.-origin items that would ultimately support Iran's weapons of mass destruction and UAV programs;
- Procuring U.S.-origin items in likely furtherance of Chinese military research;
- Contributing to Pakistan's unsafeguarded nuclear activities; and
- Working as a network to procure aerospace components for the production of UAVs which have been used by Iran to attack oil tankers in the Middle East and by Russia in Ukraine.
BIS also revised the existing entry for ICSOSO Electronics Co. Ltd. by adding seven aliases and six addresses to the entry, and removed Zhejiang Perfect New Material Co., Ltd. from the Military End User List (MEU List) on the basis of a removal request.
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