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The European Union (EU), the United States (US), United Kingdom
(UK), and others, have imposed stringent restrictions on exports to
Russia, following its invasion of Ukraine. These new controls are
intended to affect significant sectors of Russia's economy, such as
energy, aviation, aerospace and technology. Given the 2014
sanctions enforced on Russia's oil and gas exploration industry, as
a result of the Crimea invasion, has not deterred from further
aggression towards Ukraine; it is likely that there will be
incremental sanctions and controls enforced on Russia depending on
the changing severity of the situation. Below is a summary of the
expanded export controls enforced by the EU, US and UK.
European Union
On 25 February 2022, the EU extended the Russian sanctions
enforced in 2014 following the annexation of Crimea to include
specific dual-use and military items that would prohibit the
proliferation of Russia's economy through its various key
industries. The new restrictions limit any counterparty in the
European Union from selling, supplying, transporting or exporting
any items relating to these industries to an entity or individual
in Russia, or for use in Russia, although there are limited
exemptions for those working in humanitarian aid and medicine. The
new export controls listed under Annex VI in EU Regulation
2022/328, detail specific goods that are restricted for export to
Russia. They include:
Electronic devices including microprocessor microcircuits and
surface skimming acoustic wave devices, restricted for their
potential use in radar and sonar devices
Sensors and lasers including direct view imaging equipment and
semiconductor lasers, restricted for their potential use in
surveillance equipment and guided weapons
Avionics including inertial navigation systems, restricted for
their potential use in military aircraft
Marine equipment including photographic still cameras and
stroboscopic light systems restricted for their potential use in
underwater vessels to scan sea-mines and track other vessels
Aerospace and propulsion equipment including off-highway wheel
tractors, restricted for their potential use in carrying heavy duty
machinery and spacecraft parts
The emphasis on avionics, aerospace and technological goods
being restricted for export to Russia is intended to cripple the
country's ability to manufacture goods that will facilitate it's
war effort in Ukraine, as well as it's longstanding production of
goods that are then re-exported to other countries.
US export controls on Russia
On 24 February 2022, the US Bureau of Industry and Security
(BIS) expanded its existing export controls on Russia, limiting US
companies from exporting dual-use and military goods to Russia.
Controlled items in the US Commerce Control List under categories
3-9 (electronics, computers, telecommunications, sensors and
lasers, avionics, marine, aerospace and propulsion), were
restricted for export, transshipment, or re-export to Russia. In
addition to adding further restrictions on goods, the US also
confined the license requirements for export control by creating
two 'foreign direct product' (FDP) rules. As part of the new rules
the US again stressed all parties throughout the supply chain would
be responsible for the goods; first to understand if Russia is the
end-destination of the goods, or whether the goods will be
transiting through Russia, and secondly to understand the end-use
and end-user of the goods, and whether there is a potential
military application to the goods.
The US BIS also emphasized controls on exporting sensitive goods
to Donetsk and Luhansk, current warzone regions in Ukraine. These
new restrictions and the complexity of obtaining specific licenses
are expected to effectively negate companies from exporting goods
to Russia.
UK export controls on Russia
On 1 March 2022, the UK's Export Control Joint Unit announced
there would be further controls enforced on Russia, in relation to
critical-industry goods, dual-use goods and military goods. The
critical-industry goods subject to export control aligned with
those listed in the EU regulation including equipment and
components used in electronics, telecommunications and aerospace.
In addition, the UK Prime Minister confirmed all dual-use items
listed under the UK Strategic Export Control List would be banned
from export to Russia; with an aim to constrain Russia's military,
industrial and technological capabilities. In contrast to the EU
and US who stated exporters must acknowledge the true intention and
state of the end-user of the restricted goods; the UK confirmed a
ban on exports of dual-use and military items irrespective of
end-user.
Import restrictions from Russia
In order to cut Russia off from the rest of the world for its
actions against Ukraine, several states are also implementing
strict import restrictions from Russia. One of Russia's largest
exports is oil and gas, which certain countries will either
completely stop importing, such as the US, or will begin to wind
down, such as countries in the EU and the UK. Incremental steps to
limit Russia from sustaining their economy have begun, including
the exclusion of airspace for Russian aircraft, and also a ban on
any sea-going vessels connected to Russia entering UK and EU ports.
The intended outcome is that global enforced sanctions and trade
controls will discourage Russia from continuing its war on
neighbouring Ukraine.
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