The U.S. Export Administration Regulations (EAR) are key regulations in the field of U.S. export control, implemented by the Bureau of Industry and Security (BIS) of the U.S. Department of Commerce. These regulations particularly focus on the U.S. export control measures against Russia.

The EAR first clarifies which items are subject to control:

Items Subject to EAR Control and Their Special Provisions for Russia
Items Not Subject to EAR Control

Based on the Commerce Control List (CCL), the EAR lists special control measures against Russia. This includes controls based on end - users and end - uses, as well as specific embargoes and other special measures. It is worth noting that since May 23, 2023, the sanction measures for certain industries and individuals in Russia and Belarus have changed.

In order to better understand and comply with the EAR, enterprises need to pay close attention to the notices and announcements issued by BIS regarding Russia. These include statements on the Russian military - industrial complex, Russias actions in Ukraine, and other additional export restrictions on Russia and Belarus.

If an enterprises export items are subject to the control of the EAR, they must determine whether they need to apply for a license from BIS. In addition, special prohibitions against Russia, especially the special provisions under General Prohibition 10, need to be noted.

With the changes in international relations and political situations, the U.S. foreign export control strategy is also constantly being adjusted. For enterprises intending to conduct transactions with Russia, understanding and complying with the EAR is the key to ensuring the legality of their transactions and avoiding potential legal risks.