Russian Gets Its Own “Entities” List
In response to Russia’s invasion of Ukraine and its recognition of two independent states that are part of the country, the US Bureau of Industry & Security has issued a number of sanctions under the Export Administration Regulations that have been primarily reserved for individuals, institutions, and companies that the US government sees asa threat to US security. The new measures impose a Commerce Control List for Russia, adds two ‘direct product’ rules specific to Russian military end users, other than food and medicine, and Russian government and state-owned end-users. Further the rules impose export and transfer rules on the ‘so-called’ Donetsk People’s Republic and Luhansk People’s Republic regions of Ukraine and Crimea. As with other entities on the list, all transactions with list members requires a license that would be granted by the DOC.
While the full text has not been released, what we have seen so far are restrictions including items that while are not sensitive technology components, tools, or software, but can be used to produce them by Russian end-users, similar to those placed on Huawei (pvt). There are over 45 specific Russian government entities that are being added to the list, primarily research institutions, aircraft manufacturers, and similar companies, while two companies are being added after attempting to acquire US origin items in support of ‘nuclear explosive activities’. The list of ‘new entries’ is below:
Admiralty Shipyard JSC; · Aleksandrov Scientific Research Technological Institute NITI; · Argut OOO; · Communication Center of the Ministry of Defence; · Federal Research Center Boreskov Institute of Catalysis; · Federal State Budgetary Enterprise of the Administration of the President of Russia; · Federal State Budgetary Enterprise Special Flight Unit Rossiya of the Administration of the President of Russia; · Federal State Unitary Enterprise Dukhov Automatics Research Institute (VNIIA); · Foreign Intelligence Service (SVR); · Forensic Center of Nizhniy Novgorod Region Main Directorate of the Ministry of Interior Affairs; · *International Center for Quantum Optics and Quantum Technologies LLC; · Irkut Corporation; · Irkut Research and Production Corporation Public Joint Stock Company; Joint Stock Company Scientific Research Institute of Computing Machinery; · JSC Central Research Institute of Machine Building (JSC TsNIIMash); · JSC Kazan Helicopter Plant Repair Service; · JSC Rocket and Space Centre – Progress; · Kamensk-Uralsky Metallurgical Works J.S. Co.; · Kazan Helicopter Plant PJSC; Komsomolsk-na-Amur Aviation Production Organization (KNAAPO); · Ministry of Defense of the Russian Federation including the national armed services (army, navy, marine, air force, or coast guard), as well as the national guard and national police, government intelligence or reconnaissance organizations of the Russian Federation; · Moscow Institute of Physics and Technology; NPO High Precision Systems JSC; · NPO Splav JSC; · Oboronprom OJSC; · PJSC Beriev Aircraft Company; · PJSC Irkut Corporation; · PJSC Kazan Helicopters; · POLYUS Research Institute of M.F. Stelmakh Joint Stock Company; · Promtech-Dubna, JSC; · Public Joint Stock Company United Aircraft Corporation; · Radiotechnical and Information Systems (RTI) Concern; · Rapart Services LLC; Rosoboronexport OJSC (ROE); · Rostec (Russian Technologies State Corporation); · Rostekh – Azimuth; · Russian Aircraft Corporation MiG; · Russian Helicopters JSC; · *SP Kvant; · Sukhoi Aviation JSC; · Sukhoi Civil Aircraft; · Tactical Missiles Corporation JSC; · Tupolev JSC; · UEC-Saturn; · United Aircraft Corporation; United Engine Corporation; and · United Instrument Manufacturing Corporation
While the full text has not been released, what we have seen so far are restrictions including items that while are not sensitive technology components, tools, or software, but can be used to produce them by Russian end-users, similar to those placed on Huawei (pvt). There are over 45 specific Russian government entities that are being added to the list, primarily research institutions, aircraft manufacturers, and similar companies, while two companies are being added after attempting to acquire US origin items in support of ‘nuclear explosive activities’. The list of ‘new entries’ is below:
Admiralty Shipyard JSC; · Aleksandrov Scientific Research Technological Institute NITI; · Argut OOO; · Communication Center of the Ministry of Defence; · Federal Research Center Boreskov Institute of Catalysis; · Federal State Budgetary Enterprise of the Administration of the President of Russia; · Federal State Budgetary Enterprise Special Flight Unit Rossiya of the Administration of the President of Russia; · Federal State Unitary Enterprise Dukhov Automatics Research Institute (VNIIA); · Foreign Intelligence Service (SVR); · Forensic Center of Nizhniy Novgorod Region Main Directorate of the Ministry of Interior Affairs; · *International Center for Quantum Optics and Quantum Technologies LLC; · Irkut Corporation; · Irkut Research and Production Corporation Public Joint Stock Company; Joint Stock Company Scientific Research Institute of Computing Machinery; · JSC Central Research Institute of Machine Building (JSC TsNIIMash); · JSC Kazan Helicopter Plant Repair Service; · JSC Rocket and Space Centre – Progress; · Kamensk-Uralsky Metallurgical Works J.S. Co.; · Kazan Helicopter Plant PJSC; Komsomolsk-na-Amur Aviation Production Organization (KNAAPO); · Ministry of Defense of the Russian Federation including the national armed services (army, navy, marine, air force, or coast guard), as well as the national guard and national police, government intelligence or reconnaissance organizations of the Russian Federation; · Moscow Institute of Physics and Technology; NPO High Precision Systems JSC; · NPO Splav JSC; · Oboronprom OJSC; · PJSC Beriev Aircraft Company; · PJSC Irkut Corporation; · PJSC Kazan Helicopters; · POLYUS Research Institute of M.F. Stelmakh Joint Stock Company; · Promtech-Dubna, JSC; · Public Joint Stock Company United Aircraft Corporation; · Radiotechnical and Information Systems (RTI) Concern; · Rapart Services LLC; Rosoboronexport OJSC (ROE); · Rostec (Russian Technologies State Corporation); · Rostekh – Azimuth; · Russian Aircraft Corporation MiG; · Russian Helicopters JSC; · *SP Kvant; · Sukhoi Aviation JSC; · Sukhoi Civil Aircraft; · Tactical Missiles Corporation JSC; · Tupolev JSC; · UEC-Saturn; · United Aircraft Corporation; United Engine Corporation; and · United Instrument Manufacturing Corporation
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