The Department of Commerce jointly issued a TDO against Livshits, Skvortsova, and Ippolitov as well as the two shell companies – Advanced Web Services and Strandway LLC – formed to support the illegal scheme. The TDO bans the named individuals and companies from participating in transactions subject to the EAR, including exports from the United States and re-exports from abroad. The TDO will remain in effect for an additional 180 days and can be renewed. The full TDO can be found here. Notably. The indictment and TDO highlight the important work of the Office of Export Enforcement (OEE) within BIS. This elaborate scheme operated across multiple nations and was uncovered, in part, due to an OEE discovery of a transshipment point in Hamburg, Germany. This is difficult work for a small enforcement arm of the U.S. national security establishment, but OEE’s mission could be made easier in the future given that the recently enacted omnibus funding bill increased BIS’ budget by 35%. This significant increase in funding may lead to greater resources for prosecution and enforcement of export violations.
Russian and Belarusian Airlines – TDOs Renewed
On December 5, BIS renewed a TDO first issued on June 16, 2022, against Belavia Belarusian Airlines for ongoing violations of comprehensive U.S. export controls on Belarus. BIS asserted that the airline continues to operate in violation of the TDO and the regulations imposed against Belarus. The TDO bans the company from participating in transactions subject to the EAR, including exports from the United States and re-exports abroad. The TDO will remain in effect for an additional 180 days.
On December 20, TDOs against Nordwind Airlines, Pobeda Airlines, and Siberian Airlines d/b/a S7 Airlines were also renewed.
Russia-Related Designations
On December 21, Bureau of Industry and Security added the Wagner Group to the Entity List. The Wagner Group has been determined to be a Russia/Belarus ‘Military End User.’ As a result of the designation, a license from BIS is required to export or re-export to the group both U.S.-origin items and certain items produced outside the United States using U.S.-origin technology or equipment. The BIS press release can be found here. On December 8, BIS added one entity from Latvia, one entity from Switzerland, and nine entities from Russia to the EL for significant contributions to Russia’s military and/or defense industrial base. The added entities were determined to be Russia/Belarus ‘Military End Users.’ As a result of the designation, a license from BIS is required to export or re-export to the listed entities both U.S.-origin items and certain items produced outside the United States using U.S.-origin technology or equipment. The BIS press release can be found here.
For more information about BIS and OFAC designations of Russian and related entities, please see the Bass, Berry, and Sims’ Q4 Russia, Ukraine update blog.
3 International Trade Enforcement Roundup |
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