In response to Russia’s invasion of Ukraine, the U.S. government has taken swift action to impose severe export restrictions and financial sanctions on Russia, Belarus, and the Donetsk People’s Republic (DNR), Luhansk People’s Republic (LNR), and Crimea regions of Ukraine, as well as individuals and entities supporting the Russian government in these regions. These controls are intended to “severely restrict Russia’s access to technologies and other items that it needs to sustain its aggressive military capabilities.” A BIS Final Rule adds new license requirements for all Export Classification Numbers (ECCNs) in Categories 3-9 of the Commerce Control List (CCL), expands existing Russia ‘military end use’ and ‘military end user’ controls and introduces a number of other controls. BIS later issued a Final Rule adding similar restrictions for Belarus (PDF) due to the country’s ‘substantial enabling of the Russian Federation’s further invasion of Ukraine.’ Additionally, President Biden issued an Executive Order on February 21, 2022, prohibiting both import and export of goods, services, or technology with the Donetsk People’s Republic (DNR) and Luhansk People’s Republic (LNR) regions of Ukraine (with some exceptions for humanitarian efforts).
The most recent restrictions are found below (courtesy of the University of Pennsylvania, Office of Research Services). These regulations are rapidly changing and may impact current or future collaborations, shipments, travel, and financial transactions. Please be sure to contact the ORPC if you are considering or continuing collaboration with, or exporting items or data to, individuals and/or organizations in Russia, Belarus, or the Crimea, DNR, or LNR regions of Ukraine.
Shipping
FedEx, UPS, and DHL have suspended deliveries to Russia, Belarus, and Ukraine due to the current conflict in Ukraine. The U.S. Postal Service (USPS) is currently the only shipping option for these countries, although USPS may also experience interruptions or be unavailable depending upon circumstances on the ground.
Export Restrictions and License Requirements
The U.S. government has also imposed export licensing requirements for almost all items and technology being exported or re-exported to Russia or Belarus. The export licensing requirements also apply to hand-carried items, shipments, or transfer of items and technology to Russia, Belarus, or the Donetsk People’s Republic (DNR), Luhansk People’s Republics (LNR), and Crimea regions of Ukraine.
Financial Sanctions and Restricted Parties
The U.S. government has implemented blocking sanctions on most major Russian banks and placed multiple businesses and individuals on restricted parties lists due to their support of the Russian government. Financial transactions and other activities with these restricted parties may require prior authorization from the U.S. Departments of Commerce or Treasury. Please contact the ORPC for review of such entities by submitting an entity restricted party screening form. Instructions and information about this form is found here.
Please forward additional questions to the ORPC at compliance@umbc.edu.
updated 12/22/2022