On July 19, 2021, the Department of Commerce’s Bureau of Industry and Security (BIS) added six Russian entities to the Entity List for their relation to the Russian government’s “harmful foreign activities” that present a threat to the United States’ national security, foreign policy, and economy. Specifically, the entities were added to the Entity List for being a part of the Russian government’s efforts to undermine the U.S. elections, engage in malicious cyber activities against the U.S. and other foreign governments, foster transnational corruption to influence foreign governments, and pursue extraterritorial activities targeting dissidents or journalists. The six entities include:

  • Aktsionernoe Obshchestvo AST;
  • Aktsionernoe Obshchestvo Pasit;
  • Aktsionernoe Obshchestvo Pozitiv Teknolodzhiz;
  • Federal State Autonomous Institution Military Innovative Technopolis Era;
  • Federal State Autonomous Scientific Establishment Scientific Research Institute Specialized Security Computing Devices and Automation; and
  • Obshchestvo S Ogranichennoi Otvetstvennostyu NEOBIT.

Notably, these six entities were also sanctioned by the Department of the Treasury’s Office of Foreign Assets Control (OFAC) in April 2021. As such, the BIS’s action to add the six entities to the Entity List will “complement the actions already taken by OFAC by ensuring that U.S. sanctions on these entities will apply to all items subject to the EAR regardless of whether a U.S. person is involved in the transaction or whether the transaction involves the U.S. financial system.”

The Entity List is a tool used by the BIS to restrict the export, reexport, and transfer (in-country) of items subject to the EAR to entities believed to be participating in actions that go against the interests of the United States’ national security or foreign policy. Additional licenses are required for the exportation, re-exportation, and transfer of commodities, software, and technology to any listed entities. No license exceptions apply and license applications are subject to a presumption of denial.

The announcement by the BIS is available here.

For more information on Russia, EAR, and OFAC, contact our team and see previous posts below.

OFAC Revokes Belarus General License (General License 2G or GL 2G) | International Trade Law (cmtradelaw.com)

Five Charged in Scheme to Export Thermal Imaging Scopes and Night Vision Goggles to Russia, in Violation of the Arms Export Control Act | International Trade Law (cmtradelaw.com)