Russia Sanctions FAQ: Intermediaries, Including MROs

February 28, 2022 by Leave a comment

QUESTION – Intermediaries, Including MROs: I have been contacted by an MRO that wants to buy aircraft articles. The MRO is located in a country where it is legal to export most aircraft articles without an export license. Last week, though, I got the same exact purchase order from a Russian air carrier, so I strongly believe that the MRO is buying on behalf of the Russian air carrier. Can I sell to the MRO despite this belief?

Short Answer

The short answer is that this export looks like it is likely to be prohibited unless you have an appropriate export license. The reason for this is because it appears from the fact pattern that the article is intended to be installed on a foreign aircraft and the foreign aircraft appears to be subject to Russian operational control. This makes the transaction subject to the new Russia sanctions published by BIS.

Analysis

It is important to remember that there is a special rule under the U.S. export regulations that requires additional due diligence for aircraft articles destined for installation on a foreign aircraft. If you know that the article you plan to export is intended for installation on a foreign aircraft then you need to identify at least three pieces of information (per 15 C.F.R. § 744.7(a)):

  • The country in which the aircraft is located, and
  • The country in which the aircraft is registered (I usually ask for the registry number as well, for verification), and
  • Who currently controls / leases / charters the aircraft and their nationality.

Once we have this information, then we need to analyze the information to assess compliance. Each of these locations needs to be cleared (either [i] no license required, or [ii] appropriate license obtained, or [iii] license exception found to be applicable). If any one fo them leads to a license obligation, then the license obligation must be cleared (e.g. license or exception) in order to perform the export.

An Example

Let’s see how this looks in a real-world hypothetical. Imagine that you get a purchase order from an MRO in Turkey. The purchase order seeks a set of articles that are all controlled under ECCN 9A991. Imagine that the MRO reveals that the articles are intended to be installed on a Irish-registered aircraft that is leased to and operated (controlled) by a Russian air carrier. Even though you are exporting to Turkey, you also need to consider the other nations identified in this analysis. Exporting an ECCN 9A991 article to Turkey or Ireland does not require a license based on destination (we will omit the other analyses, such as party-level restrictions); however the recently-promulgated Russia sanctions do require that these articles be licensed to be exported for the purpose of installation on an aircraft subject to Russian operational control.

In this hypothetical we need to find a way to address the Russian operational control of the aircraft. Typically we might turn to the AVS license exception. The new Russian Sanctions regulations explicitly permit reliance on subsections (a) and (b) of that AVS license exception. BUT – and this is important – the AVS license exception we would use (in section 740.15(b)) cannot be used for country group D:1 nations. And Russia is a D:1 nation. So the AVS license exception for aircraft articles is unavailable for this export transaction.

Unless we have a transaction that fits into another sort of license exception, we are probably going to need a license for this transaction.

What Else Can I Do?

Information is your friend in situations like this., The more information you have, the more you can explore other options, like special exceptions that might apply to your transaction.

For example, it might turn out that the bill of materials requested is part of a service bulletin, and the fact that a Russian carrier sought the same bill of materials might be an understandable coincidence. In such a case, though, I might ask the customer-MRO to provide assurances that the articles are being installed in a manner consistent with U.S. law. I would take this additional step because of a red-flag that was raised by the similarities between the purchase orders.

You also might identify another license exception that applies to the transaction.

Some exporters might tend to prefer an information-free transaction on the grounds that what-they-don’t-know-can’t-hurt-them. This is not always true in export cases. Remaining willfully blind to the facts may not shield you from liability. Instead, willful blindness to the facts is often more likely to lead to trouble.

The most important thing for exporters to recognize is that they have a role in preventing circumvention of the U.S. export regulations. Failure to fulfill that role undermines the regulations, but it also potentially puts you in jeopardy of administrative or criminal penalties for your support of an illegal export transaction.

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Russia Sanctions FAQ: Return of Goods

February 28, 2022 by 1 Comment

QUESTION – RETURN OF GOODS: I was managing repairs for a Russian air carrier and I still have aircraft articles from Russia in my inventory.  Can I just return them to Russia?

There are new requirements that apply to this sort of transaction. Even though these requirements have not yet been published in the Federal Register, they are effective as of February 24. The new BIS requirements can be found online.

A license will typically be required for the return to Russia of anything in CCL Categories 3 through 9.  Most aircraft articles fall into an ECCN in CCL categories 3 through 9 (for example, many aircraft articles are identified in ECCN 9A991, which is in CCL Category 9).  Such articles are subject to the new licensing requirements.  So this means that you typically cannot return the articles to a Russian airline unless you obtain a license.

There is currently a presumption of denial on Russia licenses under the new BIS rules, so you will need a compelling reason to be able to obtain a license.

Only certain special license exceptions can be used to overcome this licensing provision.  15 C.F.R. § 746.8(c). For the aviation industry, the most useful of these is typically AVS, which is for aircraft parts. SPOILER ALERT: You can’t use AVS to overcome the new Russia sanctions and send something to a Russian airline for use on their planes.

The new regulations permit reliance on the first two subsections of the AVS license exception (15 C.F.R. § 740.15(a) and (b)). AVS permits the export of aircraft parts for permanent use on an aircraft, when those parts are necessary for the proper operation of the aircraft (such as parts included on the type design). Typically, to use this AVS exception you need to know the destination aircraft. This license exception does not apply to an aircraft registered in, owned or controlled by, or under charter or lease to a country included in Country Group D:1, Cuba, or a national of any of these countries. Russia is found in country group D:1, so you cannot use AVS for a Russian-owned/controlled aircraft but you could potentially use it to support a non-Russian aircraft.

The licensing obligation also generally applies to Russia-destined re-exports (such as things that started in the US, and are now contemplated to be exported from a non-US country to Russia). Your actual fact pattern can complicate things so if this is a potential issue for you, then you should be asking a lawyer for advice on your specific facts.

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BIS Issues New Regulations Implementing Sanctions Against Russia

February 25, 2022 by 3 Comments

We have written over the last few days about the implementation of new rounds of sanctions against Russia. Effective February 24, and to be published March 3 in the Federal Register, BIS has finalized its own regulation implementing sanctions measures against Russia. The goal of the sanctions is to restrict Russia’s access to items it needs to project power and includes “sophisticated technologies designed and produced in the United States, as well as certain foreign-produced items that contain or are based on U.S.-origin technology.” These controls primarily target Russia’s defense, aerospace, and maritime sectors. The following is a brief summary of BIS’s sanctions implementation.

ECCN License Requirements

The most significant change for aircraft parts distributors appears in new § 746.8(a)(1) of the EAR, which imposes a license requirement on any item subject to an ECCN in categories 3 through 9 of the CCL. This would obviously include common industry ECCNs like 9A991.d and 7A994, as well as more tightly controlled CCL 7 and CCL 9 ECCNs. Further, license applications are subject to a presumption of denial, making licenses difficult to obtain. The preamble to the regulation specifically cites ECCN 9A991.d as an example of an item subject to a low level of control that did not previously require an export license to Russia that will now require a license.

However, two notes to this general policy are important to aircraft parts distributors. First, BIS will apply a case-by-case review policy to export license applications intended to ensure inter alia safety of flight. Second, License Exception AVS paragraph (b) remains available to overcome the new license requirement. AVS paragraph (b) provides:

Equipment and spare parts for permanent use on an aircraft, when necessary for the proper operation of such aircraft, may be exported or reexported for use on board an aircraft of any registry, except an aircraft registered in, owned or controlled by, or under charter or lease to a country included in Country Group D:1, Cuba, or a national of any of these countries.

Note that Russia is a D:1 country, so AVS would not be allowed for Russian registered, owned, or operated aircraft, but non-Russian operators in AOG situations in Russia may be able to be supported under this exception.

This license exception and case-by-case review policy should allow distributors to continue to serve some civil operators in Russia (again, with the note that to support a Russian operator will require an export license), but we caution anyone seeking to use such an exception to consult with their export compliance counsel.

Additional Restrictions

Foreign Direct Product

The sanctions create two new “foreign direct product”(FDP) rules: one applicable to Russia as a whole and one applicable to Russian military end users. These restrictions apply to the export or re-export of foreign-produced items that are the product of U.S.-controlled technology or software. In the case of the FDP rule applying to Russia broadly, the relevant foreign produced products are those produced from controlled technology or software in CCL 3-9, and are subject to comparable license requirements, presumptions, and exceptions as the ECCN rule above. In the case of FDP to military end-users, all CCL chapters are restricted and no license exceptions are available (with certain very case-specific exceptions).

Expanded Military End-Use and Military End User Control

The sanctions expand the restrictions on items that can be exported without a license to Russian military end users and end-uses. Previously, those items listed in Supplement No. 2 to part 744 required a license for export to a military end use or military end user. The sanctions expand the ECCNs that require a license to a Russian military end use/user to all items subject to the EAR except food and medicine designated EAR99 and items subject to ECCNs 5A992.c and 5D992.c (and even those not to Russian government end users or state-owned enterprises). In short, practically every item subject to the EAR will require a license for export to a Russian military end user or for a Russian military end-use, and those licenses will be presumptively denied.

Russian MEU Listed Entities to the Entity List

Finally, BIS transitioned 45 Russian entities from the Military End User (MEU) list (Supplement No. 7 to part 744) to the Entity List (Supplement No. 4 to part 744; 15 C.F.R. § 744.16) to reflect the heightened restrictions and licensing requirements reflected by the expanded military end-user and end-use controls described above. BIS also added and modified certain entities.

Conclusion

This is a highly complex and dynamic regulatory environment. The baseline presumption is that all aerospace exports to Russia of virtually anything subject to the BIS regulations will require a license. For the purposes of civil aviation, license exception AVS (to non-Russian aircraft) and case-by-case license review may offer some limited relief, but make sure to consult with your export compliance counsel before undertaking any new transactions. Also remember that the sanctions and regulations continue to change: what was a legal export yesterday may not be legal tomorrow. Keep your eye on this space for more updates.

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More Russia Sanctions are on the Way

February 24, 2022 by 1 Comment

Last night, President Biden spoke with President Zelenskyy of Ukraine. In the public statement issued after the call, President Biden said that today he would be “meeting with the Leaders of the G7, and the United States and our Allies and partners will be imposing severe sanctions on Russia.”

Earlier this week we described the first round of sanctions, which were targeted at the “Covered Regions” in Eastern Ukraine. The next round of sanctions will probably described businesses and people in Russia with whom business is restricted. One of the areas of potential sanctions that is being discussed in Washington is specific export restrictions on aerospace products and articles.

In addition, Janet Yellen has signed a determination that limits financial transactions with Russia.

ASA members should be cautious about transactions with Russia and in particular should watch carefully for more export sanctions that may more directly target Russia.

UPDATE: This afternoon (Feb. 24th) President Biden announced that the United States and the G-7 will be imposing additional sanctions on Russia. Based on a recent background statement by a senior administration official, it appears likely that these will include export restrictions. As soon as the details become available, we will be posting a blog article about them.

Also, the Treasury Department issued a new directive that will restrict certain transactions with the following businesses:

x CREDIT BANK OF MOSCOW PUBLIC JOINT STOCK COMPANY
x GAZPROMBANK JOINT STOCK COMPANY
x JOINT STOCK COMPANY ALFA-BANK
x JOINT STOCK COMPANY RUSSIAN AGRICULTURAL BANK
x JOINT STOCK COMPANY SOVCOMFLOT
x OPEN JOINT STOCK COMPANY RUSSIAN RAILWAYS
x PUBLIC JOINT STOCK COMPANY ALROSA
x PUBLIC JOINT STOCK COMPANY GAZPROM
x PUBLIC JOINT STOCK COMPANY GAZPROM NEFT
x PUBLIC JOINT STOCK COMPANY ROSTELECOM
x PUBLIC JOINT STOCK COMPANY RUSHYDRO
x PUBLIC JOINT STOCK COMPANY SBERBANK OF RUSSIA
x PUBLIC JOINT STOCK COMPANY TRANSNEFT

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White House Issues Round One of the Ukraine-Russian Sanctions

February 22, 2022 by 2 Comments

The White House has announced that it will be issuing sanctions “to respond to President Putin’s action to purportedly recognize the so-called Donetsk and Luhansk People’s Republics (DNR and LNR) as “independent” states.” What does this announcement mean for ASA members who have Russian or Ukrainian business partners?

At the root of the sanctions is an Executive Order that was signed last night. It defines the “Covered Regions” as the areas covered by the Donetsk People’s Republic (DNR) and the Luhansk People’s Republic (LNR). It also authorizes the Secretary of the Treasury to identify other parts of Ukraine to be identified as a part of the Covered Regions (typically this would be accomplished through an OFAC rule, so it will be important to watch whether this scope expands to include other parts of Ukraine).

  • The Executive Order prohibits investment in the Covered Regions;
  • The Executive Order prohibits export (or other sale/supply) to the Covered Regions;
  • The Executive Order prohibits import from the Covered Regions;
  • The Executive Order prohibits participation by a United States person in a transaction by a foreign person that would have been prohibited in the United States.

The Executive Order also permits the addition of people and entities to the Specially Designated Nationals (SDN) list, so it will be important to check our business partners against this list for each export transaction (you should already be doing this).

Previously issued licenses may not cover this new Executive Order, so they may be inadequate to overcome this new Executive Order’s restrictions. Thus even a previously licensed transaction may require a new license if it is within the scope of the Executive Order.

Don’t forget that there are existing sanctions against Russia and the Crimean region. So make sure that you comply with those, as well. The White House has signaled that more sanctions may be issued, soon, against Russia; this means that keeping abreast of the changing regulations and standards is especially important.

There are special wind-down rules. If you need to engage in a wind-down operation to exit business in the Covered Regions, then make sure you consult with an attorney, and review the OFAC wind-down general license.

In summary, if you’ve been buying from or selling to a partner in a Covered Region, then you will need to assess your aircraft parts transactions to ensure that they remain in compliance with the law – full compliance may require a new license, or it may require termination of the business. I would recommend against any aircraft parts transaction that involves the Covered Regions unless you have the advice of an attorney who understand this area of the law.

Resources:

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U.S Announces new Russia Sanctions. What it means for Distributors.

April 16, 2021 by Leave a comment

Yesterday, as you are no doubt aware, the United States announced a new round of sanctions against the Government of the Russian Federation for

efforts to undermine the conduct of free and fair democratic elections and democratic institutions in the United States and its allies and partners; to engage in and facilitate malicious cyber-enabled activities against the United States and its allies and partners; to foster and use transnational corruption to influence foreign governments; to pursue extraterritorial activities targeting dissidents or journalists; to undermine security in countries and regions important to United States national security; and to violate well-established principles of international law, including respect for the territorial integrity of states.

The effect of the sanctions are to block the interests in property of certain persons (including both individuals and companies) in the technology or defense and related materiel sector, persons who have engaged in malign activities, and other persons and entities holding key roles in the Russian government or blocked entities (the full list is described in the Executive Order).

Sanctions against Russia are not a new concern for aircraft parts distributors. For many years, companies exporting to Russia have been required to review their customer and end users–as well as the individuals and entities that own or control the customers and end users–to determine whether they are subject to any of the existing sanctions regimes arising out of the situation in the Crimea region of Ukraine or other sanctions regimes imposed by the U.S. Treasury Department and administered by OFAC.

In limited cases, sanctioned persons have been corporations with a direct nexus to aviation, e.g., Rostec, Avia Group, and Avia Group Nord. In other cases, exports to entities like Aeroflot and United Aircraft Corporation may require a license depending upon facts of the transaction due to the ownership or control exercised by a sanctioned entity, like Rostec, or a high-powered individual.

The latest round of sanctions is likely to have both effects. A company called Unijet–which offers on-demand VIP business jet service–was added to the list, as well as a range of individuals and large institutions that could indirectly have a controlling interest in or position with aerospace and aviation companies.

What does all this mean for aircraft parts distributors? Unless you are doing business with one of newly listed parties, not much has changed. You already should be performing a review of your customer and obtaining detailed end user information when exporting aircraft articles to ensure compliance with OFAC sanctions (as well as BIS export regulations). When a customer, end user, or person or entity with control (more than a 50% stake) appears on the OFAC Sanctions List, you must obtain a specific license or identify an appropriate authorization prior to export.

Exports to persons in nations subject to U.S. sanctions can be tricky. Due to the nature of state-owned enterprises and monopolies, and the powerful individuals that control them, you must often dig through many layers of ownership and control to determine whether or not a blocked person is involved in the transaction. Such diligence should be memorialized in writing and kept with the other records retained for the transaction so that you can demonstrate the efforts you took to clear any red flags if the government ever asks.

Whenever you have questions about export compliance–and especially when you are dealing with customers in countries that have been subject to U.S. or international sanctions–we always recommend you consult with an export compliance attorney to help you .

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New Military-Intelligence Rules Apply to Certain Transactions

January 15, 2021 by Leave a comment

New US rules published today create new restrictions on support of certain military-intelligence end uses and end users. This will authorize the addition of new entities to the export control lists, and will also impose a de facto requirement to ensure your transactions are not supporting restricted military-intelligence end uses. This new restriction comes on the heels of new restrictions related to military end uses and military end users.

15 C.F.R. is being amended to create new restrictions on the support of certain military-intelligence end uses and end users.

The specific restrictions apply to transactions – of any item subject to the Commerce Department export regulations – because there is an unacceptable risk of use in, or diversion to, a ‘military-intelligence end use’ or a ‘military-intelligence end user’ in the People’s Republic of China, Russia, or Venezuela; or a country listed in Country Group E:1 or E:2 (currently Cuba, Iran, North Korea, Sudan and Syria).

Two key definitions are also added to the regulations, to explain the scope of the new restrictions:

‘Military- intelligence end use’ means the design, ‘‘development,’’ ‘‘production,’’ use, operation, installation (including on-site installation), maintenance (checking), repair, overhaul, or refurbishing of, or incorporation into, items described on the U.S. Munitions List (USML) (22 CFR part 121, International Traffic in Arms Regulations), or classified under ECCNs ending in ‘‘A018’’ or under ‘‘600 series’’ ECCNs, which are intended to support the actions or functions of a ‘military- intelligence end user,’ as defined in this section.

15 C.F.R. § 744.22(f)(1) (March 16, 2021).

‘Military-intelligence end user’ means any intelligence or reconnaissance organization of the armed services (army, navy, marine, air force, or coast guard); or national guard. For license requirements applicable to other government intelligence or reconnaissance organizations in China, Russia, or Venezuela, see § 744.21 of the EAR. Military-intelligence end users subject to the license requirements set forth in this § 744.22 include, but are not limited to, the following:

(i) Cuba. Directorate of Military Intelligence (DIM) and Directorate of Military Counterintelligence (CIM).

(ii) China, People’s Republic of. Intelligence Bureau of the Joint Staff Department.

(iii) Iran. Islamic Revolutionary Guard Corps Intelligence Organization (IRGC– IO) and Artesh Directorate for Intelligence (J2).

(iv) Korea, North. Reconnaissance General Bureau (RGB).

(v) Russia. Main Intelligence Directorate (GRU).

(vi) Syria. Military Intelligence Service.

(vii) Venezuela. General Directorate of Military Counterintelligence (DGCIM).

15 C.F.R. § 744.22(f)(2) (March 16, 2021).

In summary, the recent expansion to the military end use/user rules is further expanded to include military intelligence services (in the seven affected countries) as well.

The most difficult compliance target may be China, because of the complicated manner in which the private sector and the state are intertwined (and also because of the large volumes of trade between these two nations). Compliance in China in particular will require special attention to detail, and to ensuring that regulatory obligations are understood and that compliance is well-documented.

The new rules apply to both direct exports and also to certain transactions that are not U.S. exports. There are some limited, specific cases where the U.S. export laws apply to transactions that are not U.S. exports. The best known case is re-exports, where U.S. origin products that are exported from one third-country location to another are nonetheless subject to U.S. export regulations.

Another special case involves weapons of mass destruction, the restrictions for which have been summarized in subsection 730.5(d). Current regulations provide:

“(d) U.S. Person Activities. To counter the proliferation of weapons of mass destruction, the [Export Administration Regulations] restrict the involvement of “United States persons” anywhere in the world in exports of foreign-origin items, or in providing services or support, that may contribute to such proliferation.”

15 C.F.R. § 730.5(d) (2020).

In today’s Federal Register, the government expanded the scope of subsection 730.5(d) to read as follows (note that restrictions on missiles and nuclear, chemical, and biological weapons already existed in the regulations, but the text dealing with them is also expanded in the new rule change):

(d) ‘‘U.S. person’’ activities. The[Export Administration Regulations] restrict specific activities of ‘‘U.S. persons,’’ wherever located, related to the proliferation of nuclear explosive devices, ‘‘missiles,’’ chemical or biological weapons, whole plants for chemical weapons precursors, and certain military-intelligence end uses and end users, as described in § 744.6 of the [Export Administration Regulations].

15 C.F.R. § 730.5(d) (March 16, 2021).

This should be of note to ASA members because it expands the scope of this rule to include certain military-intelligence end uses and end users – which means that some transactions that are not strictly U.S. exports will nonetheless be restricted when the participants include U.S. persons.

The new regulation is an interim final regulation. It is exempt from the APA’s requirements for notice and comment so it will go into effect on March 16, 2021 without comment. In the interest of effective rule-making, the government is nonetheless collecting comments on this rule.

As always, if you think that your transactions may be affected by the new rule, please consider seeking our legal advice to support your compliance program.

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Exporting under Russia-Ukraine Sanctions

August 19, 2014 by

Recently, we have had several questions from members regarding export of aircraft parts to Russia and the Ukraine. As most readers no doubt know, the United States and the EU, in response to the conflict in eastern Ukraine, have imposed various economic sanctions on certain persons and businesses in Russia.  When sanctions like these are imposed, those companies doing business with customers in Russia and Ukraine wisely want to know whether and what type of affect these sanctions may have on their business.

Questions regarding business relations in Russian and Ukraine typically take one of two forms: The first, can I do business with the customer at all?  The second, can I export this particular part to the customer?

To answer these questions, we first need to know what sanctions have been imposed and to whom they apply. We then need to recall our basic export compliance principles and apply those principles to determine whether the part itself can be exported.  Those who have attended ASA workshops in the past may recognize these steps as part of the process of export compliance.

The United States, through the Treasury Department, has issued several rounds of sanctions directed at specific industries and parties.  For the most part, the targeted industries have been companies in the Russian financial and energy sectors, while the individuals mainly officials and individuals with ties to Vladimir Putin.

However, companies in the financial and energy sectors are the only ones that have been targeted.  Importantly, Avia Group and Avia Group Nord, business aviation groups, were also targeted with U.S. sanctions.  This means that although not yet a focal point, the aviation industry can by targeted if the United States deems it necessary, and so is a good reminder that exporters of aircraft parts need to be aware.  The Treasury Department maintains an up to date list of Ukraine-related sanctions on its website.

Although it appears that the Russian aviation sector has not been highly targeted by the United States yet, these sanctions illustrate the importance of knowing your customer. Further, simply because the United States has not sanctioned an organization does not mean they may not be sanctioned by another body.  For instance, the EU recently issued sanctions against Dobrolet, a low-cost Russian carrier.  If you are based in the the EU, you should review the European Union’s restrictive measures in force to ensure you remain compliant with EU sanctions.

As our industry well knows, wealthy entities and individuals, such as those named in sanctions, frequently own or operate their own aircraft.  Given the wealth and high-ranking status of individuals and companies named, it is  important to review the Treasury Department Office of Foreign Asset Control’s Specially Designated Nationals list.  Furthermore, it is important to take this step with every transaction, because new individuals and entities can be added at any time, whether announced as a new round of sanctions or not.

Once we have determined whether sanctions apply to our prospective customer, we can rely on our export compliance program to take us the rest of the way.  The exporter must determine whether the article it plans to export is ITAR or EAR controlled.  Once the appropriate export regime is determined the exporter must determine whether an export license is required for the particular part or whether any license exceptions apply.  If a license is required, the exporter should apply as usual.  Be aware that both the State Department DDTC and the Commerce Department BIS may deny export license applications for high-tech items that could contribute to Russian military capability.  In most cases, however, articles for civil aviation may still be exported.

The highly publicized nature of these sanctions rightfully causes many companies to hesitate before undertaking an export transaction to the listed countries.  This hesitation is appropriate, given the already complex nature of export compliance. But these delays can also help the exporter to ensure that the transaction is undertaken correctly and legally.

The good news is that an effective export compliance system will enable you to easily comply with whatever sanctions and restrictions are enacted.  An effective compliance system should find the exporter following the same steps, reviewing the same lists, and performing the same analyses with every export transaction.  An export compliance program that is second nature to the exporter’s employees will ensure that no matter what sanctions are issued, or against whom, your company will remain compliant. Our law firm has helped many companies establish effective export compliance programs.  If you have questions regarding compliance, please feel free to contact us.

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