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Commerce Adds 120 Entities in Russia and Belarus to the Entity List, Further Limiting the Russian and Belarusian Militaries’ Access to Items That Support Aggression Against Ukraine


The U.S. Commerce Department, through its Bureau of Industry and Security (BIS), has taken additional action to degrade Russian and Belarusian defense, aerospace, maritime, and other strategic sectors in response to Russia’s brutal assault on the sovereignty of Ukraine. 

BIS is issuing a final rule adding 120 entities to the Entity List. Ninety-five (95) entities are being added as military end-users under the destinations of Belarus (24 entities) and Russia (71 entities) for acquiring and attempting to acquire items subject to the Export Administration Regulations (EAR) in support of Belarus’s and Russia’s militaries. Twenty-five (25) entities also are being added under the destination of Russia for acquiring and attempting to acquire items subject to the EAR in support of Russia’s military modernization efforts.  

“Vladimir Putin’s decision to attack Ukraine has isolated his country and economy from global commerce, and today’s action furthers that isolation by adding 120 Russian and Belarusian parties in the aerospace, maritime, and defense sectors to the Entity List,” said Secretary of Commerce Gina M. Raimondo. “These parties are being effectively cut off from the inputs necessary to sustain Putin’s war and shows that the United States has the capabilities to detect, identify, and restrict parties in Russia, Belarus, or elsewhere that seek to support that effort.”

“Today’s action demonstrates America’s resolve in support of Ukraine. We will work to detect, identify, and cut off parties that support Putin’s war effort company by company or person by person if we have to,” said Deputy Secretary of Commerce Don Graves. “The Department of Commerce will leave no stone unturned when it comes to restricting access to U.S. commodities, software, and technologies to the Russian war machine and its enablers.”

“Parties that have thrown in their lot with Vladimir Putin’s horrific assault on Ukraine should not benefit from access to U.S. items,” said Assistant Secretary of Commerce for Export Administration Thea D. Rozman Kendler. “BIS will continue its dogged scrutiny of the defense, aerospace, maritime, and other key sectors in Russia and Belarus. We will not hesitate to revoke access to U.S. items from any party seeking to support Putin’s war.”

This rule applies a highly restrictive policy of denial for the review of license applications for exports, reexports, and transfers (in-country) to the listed entities of all items subject to the EAR and prohibits the use of all license exceptions for such transactions. Additionally, the 95 ‘military end users’ are being designated under Footnote 3 of the Entity List—a designation added in the Russia export control measures that became effective February 24, 2022.  Footnote 3 entities are subject to the Russian/Belarusian Military End User foreign-produced “direct product” rule (“Russia/Belarus MEU FDP Rule”) that applies to reexports, exports from abroad, and transfers (in-country) of certain foreign produced items based on controlled U.S. technology, software, or tooling. Application of the Russia/Belarus MEU FDP Rule to these entities tremendously expands the universe of commodities, software, and technologies that they will be unable to obtain in the global market.

These actions strengthen our ongoing efforts to degrade Russia’s ability to acquire the items it needs to sustain its military aggression. These additions follow the recent addition to the Entity List of 91 entities in 10 countries on March 4, 2022, based upon their involvement in, contributions to, or other support of the Russian security services, military and defense sectors, and military and/or defense research and development efforts. In total, BIS has added 260 entities to the Entity List in response to Russia’s invasion of Ukraine. 

The 120 entities were added to the Entity List upon a determination by the interagency End-User Review Committee made up of representatives from the Departments of Commerce (Chair), Defense, State, and Energy, who evaluate potential Entity List additions based on applicable legal standards.

These BIS actions were taken under the authority of the Export Control Reform Act of 2018 and its implementing regulations, the Export Administration Regulations (EAR).

The rule is effective April 1, 2022. A link to text of the rule is available on the Feder Register’s website at: https://www.federalregister.gov/public-inspection/2022-07284/additions-of-entities-to-the-entity-list

Additional information on BIS’s actions in response to Russia’s invasion of Ukraine are available here: https://bis.doc.gov/index.php/policy-guidance/country-guidance/russia-belarus

For more information visit: https://www.bis.doc.gov 

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