Introduction

Since February 2022, US sanctions against Russia have taken on an unprecedented scale. They are developed and applied by several Departments in the United States. The US Department of Commerce is playing a vital role in this campaign.

The US Department of Commerce and Its Role in US Sanctions Against Russia

The US Department of Commerce – https://www.commerce.gov – plays a prominent role in enacting and enforcing US sanctions on the trade and export of goods and services from the United States. Together with the Office of Foreign Assets Control (OFAC) of the US Department of the Treasury, the US Department of Justice, and the US Department of State, the Department of Commerce implements the sanctions policy of the United States.

Such policies are determined and approved by the US Congress in the form of Laws and by the President of the United States in the form of Executive Orders. Then, the above Departments, each in its area, accept their regulations for implementing the US sanctions policy and further monitor them. The role of the US Department of Commerce in sanctions policy is determined by monitoring compliance with sanctions in international trade, primarily in the field of exports from the United States. In other words, this Department ensures the implementation of the policy of the US administration to prevent the export of goods, technologies, and services prohibited by sanctions.

Bureau of Industry and Security

The Bureau of Industry and Security plays a central role in implementing the sanctions policy of the US Department of Commerce. This division of the Department of Commerce publishes its Entity List , which contains a list of countries, including Russia, as well as companies that are sanctioned. It also contains requirements for licensing certain products and services intended for export, re-export, or some other transfer method to a sanctioned organization.

The purpose of such licensing is primarily to prevent countries under US sanctions from obtaining advanced technologies and products that can be used for military purposes or both peaceful and military purposes, that is, dual use.

Who Needs a US Department of Commerce License

The Department’s license is required for any organization or individual who intends to export, re-export, or otherwise transfer technology, machinery, or other prohibited goods and services. The Department’s Entity List provides, next to the name of the sanctioned entity, a list of licenses that must be obtained to deliver the relevant goods or services to that addressee. Thus, US Department of Commerce sanctions are defined per product line, as well as per services and their end users.

Conclusion

If you need to apply to the US Department of Commerce for a license, or if you need advice on another sanctions issue, please get in touch with us . Whether it is delisting from the US sanctions list or developing a preventive plan to avoid US sanctions, we are ready to assess your situation and offer an appropriate solution.