Complying with Sanctions and Export Controls in Russia and Belarus
August 3, 2022
Agnes Pawelkowska is an International Trade Specialist at the International Trade Administration’s Office of Russia, Ukraine and Eurasia.
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This blog is part of an ongoing series designed to provide U.S. exporters with information and resources on developments pertaining to U.S. sanctions and export controls in response to Russia’s aggression against Ukraine. Regulations and market conditions can change with little notice. Companies are encouraged to reach out to the Points of Contact listed at the end of this article for latest information.
As discussed in our previous blog, Russia’s unprovoked attack on Ukraine and the subsequent Western sanctions and export controls imposed have forced U.S. exporters to rethink the way they perceive the Russian market and conduct business in the country. It has also prompted all of us at the International Trade Administration (ITA) to consider how best we can support U.S. exporters as they seek to ensure their businesses are in compliance with the relevant laws and regulations. As such, ITA’s Office of Russia, Ukraine and Eurasia has compiled and centralized a series of resources that may be of assistance to U.S. exporters. Please see the complete document on the ITA Russia web page for additional details and read on for a high-level overview of the resources that the document contains.
U.S. Government Information & Resources
- While the United States government has imposed significant sanctions and export controls on Russia in response to its unlawful aggression against Ukraine, some U.S. companies can still do business in Russia.
- In addition to sanctions and export controls on Russia, the U.S. government has also imposed stringent restrictions on Belarus, including new export controls, in response to its substantial enabling of Russia’s attack on Ukraine.
- The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) is the lead agency for implementing and enforcing sanctions. The Department of Commerce’s Bureau of Industry and Security (BIS) and its Export Administration Regulations (EAR) are the lead agents for implementing and enforcing export controls.
- Humanitarian aid, agricultural commodities, medicine, medical devices, and telecommunication devices which support the free flow of information are generally exempt from export controls.
- Apart from the above, to see if your transaction is affected, check out end users on the Consolidated Screening List (CSL) on ITA’s website. A search tool and a downloadable list are available.
- Make sure your product is properly classified and does not require a BIS license due to expanded export controls against Russia and Belarus. To find out more, call an export counselor at (202) 482-4811(Washington D.C. outreach office), or at (949) 660-0144 (Western regional office), or e-mail EXDOEXS@bis.doc.gov.
- To see lists of sanctioned persons and sanctions programs, check out the OFAC website.
- Check with your financial institution before contracting for payment from Russia. More than 80% of Russia’s financial sector is currently sanctioned by the United States.
General Recommendations for U.S. Exporters Considering Russia or Belarus
- Sign up for automatic e-mail notifications from OFAC.
- Check the Federal Register for BIS, OFAC, and other USG actions and set up an account that will allow you to receive automatic e-mail notification of U.S. government actions regarding Russia.
ITA Points of Contact
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