More Russia Sanctions Highlight the Importance of the Consolidated Screening List

The Bureau of Industry and Security (BIS) will be publishing a new list of Russia-sanctions targets next week. This list includes aerospace companies outside of Russia! This highlights the importance of checking your export business partners against the consolidated screening list for EVERY transaction.

Here is just a small portion of the companies that are being added to the sanctions lists, to show you that aerospace is part of the sanctions plan:

• State Governmental Scientific Testing Area of Aircraft Systems (GkNIPAS)
• Federal State Enterprise State Research and Testing Ground for Aviation Systems named after L.K. Safronov
• Incoff Aerospace S.R.O.
• Russian Space Systems (RKS)

There are also numerous research and development facilities that have been added to the BIS restricted lists. In all of these cases, there is a presumption of denial on license applications.

In addition, it appears that ship-building, oil & gas, and telecommunications industries are also being targeted in this latest round of sanctions.

The new sanctioned entities are expected to be published in the Federal Register on March 9; however the sanctions will relate back to the first date on which they were made ‘available’ to the public. They were placed on-line late last night so expect the sanctions to apply as of March 3, 2022!

We strongly recommend checking your business partners against the consolidated screening list for EVERY export transaction. Even if you checked them for a transaction yesterday, you should check them again today to make sure that they remain clear for today’s transaction.