New Export Restrictions and Controls

Today the U.S. government announced that it would be sanctioning additional Russian entities. The new sanctions come from several different agencies, so this blog post is divided by agency. The blog post also covers some other changes to the export standards.

OFAC

The new sanctions from the Office of Foreign Asset Control (OFAC) include a number of Russian aviation businesses:

• “Joint Stock Company Prepreg Advanced Composite Materials, a Russia-based company that produces an assortment of materials used in aircraft engineering.
• Limited Liability Company Alabuga-Fibre, a Russia-based company that produces various types of carbon fibers used in aerospace and aircraft engineering.
• Limited Liability Company Prepreg-Dubna, a Russia-based company that produces an assortment of materials used in aircraft engineering.
• Joint Stock Company Research Institute of Graphite-Based Materials NIIGRAFIT (NIIGRAFIT), a Russia-based research institution and company that was created for the study and development of special types of carbon materials and products. NIIGRAFIT also produces materials used in rocket and space technology and the aviation industry.
• Joint Stock Company the Urals Scientific Research Institute of Composite Materials, a Russia-based research institution and company that specializes in research, development, and fabrication of composite goods for rocket-and-space hardware.”

This is just a small part of the 22 individuals and 83 entities that were added to the sanctions lists. The new sanctions also include businesses that produce metals and carbon fibers for the aviation industry.

The U.S. Treasury Department called today’s announcement “one of its most significant sanctions actions to date.” The sanctions announcements coincide with the one-year anniversary of the Russian “Special Military Operation” in the Ukraine

BIS

Today, BIS published a new final rule that makes minor modifications to the export rules. Here are some highlights that could affect aviation:

• ECCN 9A004.g now controls aircraft that are specially designed or modified to be air-launch platforms for sub-orbital craft.
• Fluorinated silicone fluids were previously controlled under 1C006.b.2 but are now considered EAR99. These can be used as lubricants or fuel additives in aerospace. This does not appear to affect fluorinated silicone in a solid form, such as when used in a seal.
• Imposes new limits for license exception STA, including as it applies to certain hot section technology
• Refines the technology controls that apply to technology for certain engine parts including blades, vanes, tip shrouds, combustors, etc.).

On Monday, BIS is expected to publish an order that adds new entities to the denied entities list. All of the new entities are listed because of their support of the Russian military. They are organized by country, here:

Canada

• CPUNTO Inc., and
• Electronic Network Inc.

China

• AOOK Technology Ltd.,
• Beijing Ti-Tech Science and Technology Development Co.,
• Beijing Yunze Technology Co., Ltd.,
• China HEAD Aerospace Technology Co., and
• Spacety Co. Ltd.

France

• China HEAD Aerospace Technology Co.

Luxembourg

• Spacety Co., Ltd.

Netherlands

• China HEAD Aerospace Technology Co.

Russia

• Dexias Industrial Products and Trade Limited Company,
• Innovation and Technologies LLC, and
• Promtekhkomplekt JSC.