Regulation

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

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 Admi...

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