Russia/Belarus/Ukraine-Related Sanctions

The U.S. Government has imposed a variety of significant financial and export/import sanctions on Russia, Belarus, and parts of Ukraine. Some of these sanctions may impact certain University personnel and activities. Members of the research and educational community having or planning activities involving Russia, Belarus, or Ukraine should contact the Export Controls Office (ECO) as early as possible, and definitely before attempting to send any tangible goods, software, technologies, or funds to recipients located in these countries. The ECO will assess the applicable restrictions, summarized below, and explore potential options for requesting U.S. Government authorization.
 

Export and Re-Export Restrictions for Russia & Belarus

The U.S. Department of Commerce’s Bureau of Industry (BIS) and Security has amended the Export Administration Regulations to generally prohibit the direct and indirect export of a variety of microelectronics, telecommunications items, sensors, navigation equipment, avionics, marine equipment, aircraft components, and related technology and software to Russia and Belarus. BIS has also banned exports of luxury goods, including certain apparel, alcoholic beverages, tobacco products, cosmetics, jewelry, and other specified items, to these two countries.

Anyone planning to ship or carry tangible goods, software, or technology to Russia or Belarus must first consult with the ECO. Not all items are covered by the new restrictions, but determining which items are subject to which specific requirements requires a case-by-case technical regulatory analysis conducted by the ECO.

Due in part to these export restrictions, FedEx, UPS, and DHL have suspended all shipping services to Russia until further notice. Passenger air travel into and out of Russia also has grown extraordinarily difficult and expensive, both because certain countries are choosing to suspend flights and because U.S. export controls are impacting the movement and maintenance of commercial aircraft.
 

Financial and Banking Restrictions

On February 26, the White House announced multilateral plans to remove select Russian banks from the international SWIFT messaging system, and to block the Russian Central Bank from making use of its international currency reserves. The U.S. Department of the Treasury’s Office of Foreign Assets Control has also imposed targeted sanctions against various banking groups, corporations, government organizations, and individuals in Russia and Belarus. Moreover, the White House prohibited the “exportation, reexportation, sale, or supply, directly or indirectly, from the United States, or by a United States person, wherever located, of U.S. dollar-denominated banknotes to the Government of the Russian Federation or any person located in the Russian Federation,” among other transactions, on March 11.

University students, staff, and faculty are likely to find that many transactions—payments relating to tuition, external sales, IP licenses, sponsored projects, purchases, credit/debit card use, etc.—involving accounts located in Russia or Belarus are becoming extraordinarily difficult or even impossible to complete. Any University employee planning to send or receive money to or from Russia or Belarus must consult first with the ECO.

 

Export/Import Restrictions for Certain Regions in Ukraine

Executive Order 14065 imposes a general prohibition on exports and imports to and from the “so-called Donetsk People’s Republic (DNR) or Luhansk People’s Republic (LNR) regions of Ukraine” (as was already the case for the Crimea region). This default prohibition applies to all “goods, services, or technology,” regardless of whether money is changing hands. Travel, shipments, and collaborations involving the Crimea, Donetsk, or Luhansk region must have prior ECO approval.

Due in part to these restrictions, FedEx, UPS, and DHL have suspended all shipping services to and from Ukraine until further notice.

Although the U.S. Government has not added specific universities in the restricted regions to a federal restricted parties list, the ECO has provisionally identified the following academic institutions as falling within the scope of the export/import restrictions:
 

Universities in Crimea Region

 

Universities in Donetsk Region

 

Universities in Luhansk Region