The US Bureau of Industry and Security (“BIS”) – “in response to the Russian Federation’s (Russia’s) further invasion of Ukraine, and Belarus’s substantial enabling of Russia’s invasion,” –has imposed “restrictions on the export, reexport, or transfer (in-country) to or within Russia or Belarus of ‘luxury goods’ under the Export Administration Regulations (EAR) and for exports, reexports and transfers (in-country) worldwide to certain Russian or Belarusian oligarchs and other malign actors suppo...
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