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Thompson Hine LLP, a full-service business law firm with approximately 400 lawyers in 11 offices, was ranked number 1 in the category “Most innovative North American law firms: New working models” by The Financial Times and was 1 of 7 firms shortlisted for The American Lawyer’s inaugural Legal Services Innovation Award. The firm has been recognized by the National Law Journal as a Legal Technology Trailblazer and featured by Bloomberg for its innovative service delivery models, which drive accuracy and predictability. The firm’s commitment to innovation is embodied in Thompson Hine SmartPaTHTM – a smarter way to work – predictable, efficient and aligned with client goals. For more information, please visit ThompsonHine.com and ThompsonHine.com/SmartPaTH.

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The Department of Commerce&rsquo;s Bureau of Industry and Security (BIS) issued on May 9, 2022, a <a href="https://public-inspection.federalregister.gov/2022-10099.pdf" target="_blank" rel="noopener">Final Rule</a> that greatly expands the list of items requiring a license to export to Russia. The export restrictions impact a broad range of inputs and products including wood products, industrial engines, boilers, motors, fans, and ventilation equipment, bulldozers, and many other items with industrial and commercial applications. These export control measures build upon the export controls and restrictions effective on <a href="https://www.bis.doc.gov/index.php/documents/federal-register-notices-1/2925-87-fr-12856-expansion-of-industry-sector-sanctions-on-public-display-and-effective-3-3/file" target="_blank" rel="noopener">March 3, 2022</a> (i.e., the Russian Industry Sector Sanctions rule codified at <a href="https://www.ecfr.gov/current/title-15/subtitle-B/chapter-VII/subchapter-C/part-746/section-746.5" target="_blank" rel="noopener">15 C.F.R. 746.5</a>). See Update of <a href="https://www.thompsonhinesmartrade.com/2022/03/bis-expands-russia-oil-industry-sanctions-and-adds-russian-companies-to-the-entity-list/">March 7, 2022</a>. The March 3 rule created Supplement No. 4 to Part 746, which is a list of items primarily related to the oil sector and subject to a license requirement for export, reexport, and transfers (in-country) to or within Russia.
This final rule amends the Russian Industry Sector Sanctions to further expand the Supplement No. 4, by adding an additional 205 Harmonized Tariff Schedule codes at the 6-digit level and 478 corresponding 10-digit Census Schedule B numbers. BIS notes that this is intended to better align U.S. export controls with European Union controls. BIS further stated that it will continue to review any license applications for the export of any Supplement No. 4 items under a &ldquo;policy of denial.&rdquo;
Shipments of items en route aboard a carrier to a port of export, reexport, or transfer (in-country) on May 9, 2022, pursuant to actual orders for export, reexport, or transfer (in-country) to or within a foreign destination for which, prior to May 9 no license was required or a License Exception had been available, may proceed to that destination under the previous eligibility.

core/freeform

SmarTrade

Senior Legislative and Regulatory Policy Advisor

Scott E. Diamond

Partner

Francesca M.S. Guerrero

Samir D. Varma

International Trade

BIS Expands Russian Export Controls: Significant Expansion of Supplement No. 4 List