Updated List Continues Effort to Notify Public that Providing Any Form of Service to These Aircraft is Also a Likely Violation of U.S. Law

WASHINGTON, D.C. – Today, Bureau of Industry and Security (BIS) Assistant Secretary for
Export Enforcement Matthew S. Axelrod issued an order denying the export privileges of a fifth
Russian airline – Rossiya Airlines – due to ongoing export violations related to comprehensive
export controls on Russia imposed by the Commerce Department. This Temporary Denial Order
(TDO) terminates the right of Rossiya to participate in transactions subject to the Export
Administration Regulations (EAR), including exports and reexports from the United States.
Today’s TDO is issued for 180-days and may be renewed.

“Our powerful coordination with our international partners is cutting off Russia’s ability to
acquire the parts and inputs it needs to sustain its military aggression, and today’s action furthers
the enforcement efforts necessary to ensure those restrictions are complied with.” said Under
Secretary of Commerce for Industry and Security Alan Estevez. “Today’s TDO on Rossiya
is another strong message to Putin’s government that the U.S. will remain vigilant and will not
hesitate to our law enforcement tools against Russian companies and individuals that violate the
law.”

“Today’s actions are a reminder to parties in Russia as well as throughout the rest of the world
that U.S. legal authorities are substantial, far-reaching, and have a meaningful impact on global
operations by parties found to be in violation of U.S. law.” said Assistant Secretary of
Commerce for Export Enforcement Matthew S. Axelrod. “Export Enforcement will continue
to take swift action to deny Russian airlines and oligarchs the means to continue to operate
aircraft in violation of U.S. export regulations.”

BIS also publicly identified additional aircraft in likely violation of U.S. export controls,
including a 787 Dreamliner owned by Russian oligarch Roman Abramovich. This is the second
plane owned by Abramovich identified by BIS, and today’s listing notifies the public that
providing any form or service to this aircraft subject to the EAR requires U.S. Government
authorization. BIS is further updating the tail numbers of planes already on the list that have
flown into Russia and/or Belarus in apparent violation of the EAR. 

BIS has led the Department of Commerce’s efforts in response to Russia’s invasion of Ukraine
by taking a number of powerful regulatory actions and issuing public notice to the global
community of potential violations of the EAR in the civilian aerospace sector. As part of those
actions, the TDO against Rossiya prevents the export or reexport of any EAR item to Rossiya
without BIS authorization, as well as the use of any EAR items to service any Rossiya aircraft.
BIS has previously issued TDOs for Aeroflot, Azur Air, UTair, and Aviastar.

BIS continues its efforts to notify the public that providing any form of service to aircraft subject
to the EAR that may have violated these controls on Russia or Belarus requires authorization.
Absent such authorization, any person anywhere—including within Belarus or Russia—risks
violating the EAR and would be subject to BIS enforcement actions, which could include
substantial jail time, fines, loss of export privileges, or other restrictions. By preventing these
aircraft from receiving any service, including from abroad, international flights from Belarus or
Russia on these aircraft are effectively grounded.

Effective March 2, 2022, BIS imposed expansive and stringent controls on aviation-related items
destined to Belarus, including for specified aircraft or aircraft parts, similar to those imposed on
Russia on February 24, 2022. The March 2, 2022, rule also removed license exception
availability for any aircraft registered in, owned, or controlled by, or under charter or lease by
Russia or a national of Russia, thus imposing a license requirement for Russian owned/operated
aircraft. An aircraft subject to the EAR that is owned, leased or controlled by a Russian national
is prohibited from using a license exception for flights to Russia regardless of dual nationality, or
most recent citizenship, of the Russian national.

On April 8, 2022, BIS issued a rule that similarly removed license exception availability for any
aircraft registered in, owned, or controlled by, or under charter or lease by Belarus or a national
of Belarus, also imposing a license requirement for these Belarusian owned/operated aircraft. As
a result, any aircraft manufactured in the United States, or that is manufactured in a foreign
country and includes more than 25% U.S.-origin controlled content, is subject to a license
requirement if such aircraft is destined for Belarus or Russia.

The list below has been updated (with additions in bold) and currently totals 157 Russian owned/operated aircraft. Accordingly, any subsequent actions taken with regard to any of the
listed aircraft, including, but not limited to, refueling, maintenance, repair, or the provision of
spare parts or services, are subject to the prohibitions outlined in General Prohibition Ten of the
EAR (Section 736.2(b)(10)), which provides:

(10) General Prohibition Ten - Proceeding with transactions with knowledge that a
violation has occurred or is about to occur (Knowledge Violation to Occur). You may
not sell, transfer, export, reexport, finance, order, buy, remove, conceal, store, use, loan,
dispose of, transport, forward, or otherwise service, in whole or in part, any item subject
to the EAR and exported or to be exported with knowledge that a violation of the Export
Administration Regulations, the Export Administration Act or any order, license, License
Exception, or other authorization issued thereunder has occurred, is about to occur, or is
intended to occur in connection with the item. Nor may you rely upon any license or
License Exception after notice to you of the suspension or revocation of that license or exception.                                There are no License Exceptions to this General Prohibition Ten in part 740
of the EAR.

Please note this list is not exhaustive and the restrictions also apply in any situation in which a
person has knowledge that a violation of the EAR has occurred, is about to occur, or is intended
to occur in connection with an aircraft or other item that is subject to the EAR, whether or not
such aircraft or other item is included on this list. This list will continue to be updated as
circumstances warrant.

Additional BIS resources on export controls implemented in response to Russia’s invasion of
Ukraine are available at:
https://bis.doc.gov/index.php/policy-guidance/country-guidance/Russia-b…

The public may submit confidential enforcement tips via the BIS website:
https://www.bis.doc.gov/index.php/component/rsform/form/14?task=forms.e…,
or by calling the Enforcement Hotline at 1-800-424-2980.

These BIS actions were taken under the authority of the Export Control Reform Act of 2018 and
its implementing regulations, the Export Administration Regulations (EAR).

                                       For more information, visit www.bis.doc.gov.