Regulation

New guidance to prevent diversion in support of Russia’s war program

Issue 37.
October 2023

Author
Jack R. Hayes
+ About author

Jack Hayes is a Partner at Steptoe LLP, focusing on US export controls and sanctions, including the ITAR. www.steptoe.com

STEPTOE: OUTSIDE COUNSEL
Over the past month, the US government and allied govern­ments have issued important guidance about specific high-priority items being diverted through third countries and intermediaries in support of Russia’s invasion of Ukraine.
First, on 14 September 2023, the US Department of Commerce, Bureau of Industry & Security (“BIS”) issued new guidance1 regarding export controls, including those implemented under Part 744 and 746 and section 734.9 of the Export Administrat...

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