United States: BIS names six Russian organizations from list of entities already designated as Specially Designated Nationals

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On July 19, 2021, the Bureau of Industry and Security (“BIS”) of the United States Department of Commerce issued a final rule (“Final Rule”) adding six Russian organizations to the list of entities. These designations are linked to Executive Decree 14024, “Blocking Property With Respect To Specified Harmful Foreign Activities of the Government of the Russian” (“EO 14024”) which was signed by President Biden in April 2021. EO 14024 authorizes the imposition of sanctions in response to the efforts Russians who threaten an American national security, including against a wide range of parties involved in the technology and defense sectors of the Russian economy. A license from BIS will be required to export, re-export or transfer to or through these parties any item (i.e. goods, software, technology) subject to the Export Administration Regulations (“EAR”), subject to a refusal policy.

According to the final rule, these Russian parties were added to the entity list for acting contrary to the national security of the United States. The Treasury Department’s Office of Foreign Assets Control (“OFAC”) placed the six entities on its Specially Designated Nationals and Stranded Persons list earlier this year. See our previous blog post on these developments here. The fact that the BIS designated Russian parties to the entity list that were recently designated as Specially Designated Nationals may indicate a return to the Obama-era policy of regularly adding to the entity list those parties that were designated as SDN under the Obama era.

The final rule also updates the entry in the Entity List for the Federal Security Service (“FSS”) to reflect the exclusion of activities now permitted under General Cyber ​​License 1B (“GL 1B”). GL 1B was updated by OFAC in March 2021 when additional US sanctions were imposed on the Federal Security Service (“BIS”). A BIS license is required for all items subject to EARs destined for the FSS, except transactions authorized by GL 1B.

The authors thank Ryan Orange for his help in preparing this blog post.


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