U.S. Sanctions and Export Controls on Russia

Updated 4/18/22

In March 2022, the U.S. government implemented a “sweeping series of stringent export controls” and expansive sanctions against Russia in response to Russia’s invasion of Ukraine. As highlighted in the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) press release (PDF) (external link), these export controls are intended to “severely restrict Russia’s access to technologies and other items that it needs to sustain its aggressive military capabilities.” The BIS Final Rule (PDF) (external link) adds new license requirements for all Export Classification Numbers (ECCNs) in Categories 3-9 of the Commerce Control List (CCL), expands existing Russia ‘military end use’ and ‘military end user’ controls and introduces a number of other controls. BIS later issued a Final Rule adding similar restrictions for Belarus (PDF) (external link) due to the country’s ‘substantial enabling of the Russian Federation’s further invasion of Ukraine.’  On April 14^th, an additional BIS Final Rule “Expansion of Sanctions Against Russia and Belarus Under the Export Administration Regulations (EAR)” (PDF) (external link) was released in response to the ongoing aggression in Ukraine. The new rule expands license requirements for Russia and Belarus under EAR to all items on the Commerce Control List (CCL).

Additionally, an Executive Order issued on February 21, 2022 (external link) prohibits both import and export of goods, services, or technology with the Donetsk People’s Republic (DNR) and Luhansk People’s Republic (LNR) regions of Ukraine (with some exceptions for humanitarian efforts).

It is important for all members of our communities to be aware of these significant regulatory changes and work with the export control staff in the Office of Research Compliance (ORC) when considering or continuing collaboration with, or exporting items or data to, individuals and/or organizations in Russia, Belarus, or the Crimea, DNR, or LNR regions of Ukraine. Please direct questions and requests for review to um.export@maine.edu.

Resources

U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issues final rules implementing sanctions against Russia and Belarus under the Export Administration Regulations (EAR)

• BIS Press Release “Commerce implements sweeping restrictions on exports to Russia in response to further invasion of Ukraine” (PDF) (external link) – Feb. 24, 2022
• BIS Fact Sheet (PDF) (external link) – Feb. 24, 2022
• BIS Final Rule “Implementation of Sanctions Against Russia under the Export Administration Regulations (EAR)” (PDF) (external link) – Effective Feb. 24, 2022
• BIS Final Rule “Imposition of Sanctions Against Belarus Under the Export Administration Regulations” (PDF) (external link) – March 3, 2022
• BIS Final Rule “Expansion of Sanctions Against Russia and Belarus under the Export Administration Regulations (EAR)” (PDF) (external link) –  April 14, 2022

U.S. Department of Treasury Office of Foreign Assets Control (OFAC) announces expansive sanctions against Russia

• OFAC Press Release “U.S. Treasury announces unprecedented & expansive sanctions against Russia, imposing swift and severe economic costs” (external link) – Feb. 24, 2022
• Department of Treasury’s Office of Foreign Asset Control (OFAC) Ukraine-/Russia-related Sanctions page (external link) – updated Feb 24, 2022

Presidential Order issued February 21, 2022 related to the Donetsk People’s Republic (DNR) and Luhansk People’s Republic (LNR) regions of Ukraine

• White House Fact Sheet: Executive Order to Impose Costs for President Putin’s Action to Recognize So-Called Donetsk and Luhansk People’s Republics (external link) – Feb. 21, 2022
• Executive Order on Blocking Property of Certain Persons and Prohibiting Certain Transactions with Respect to Continued Russian Efforts to Undermine the Sovereignty and Territorial Integrity of Ukraine (external link) – Feb 21, 2022