WASHINGTON, D.C. – On October 13, 2022, Assistant Secretary for Export Enforcement Matthew S. Axelrod issued an order (link) denying the export privileges of Russian Airline URAL Airlines JSC (URAL) 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 this airline to participate in transactions subject to the Export Administration Regulations (EAR), including exports and reexports from the United States. This TDO is issued for 180 days and may be renewed.

“This Temporary Denial Order marks the tenth TDO issued against Russia and Belarus’s biggest airlines since Russia’s brutal invasion of Ukraine,” said Assistant Secretary of Commerce for Export Enforcement Matthew S. Axelrod. “Today’s action highlights the peril and consequences of attempting to circumvent our comprehensive export controls, and further impairs Russia’s aviation sector.”

The severe restriction in export privileges of these companies is 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 access to global commerce by parties found to be in violation of U.S. law.

URAL has engaged in and continues to engage in recent conduct prohibited by the EAR by operating controlled aircraft subject to the EAR without the required BIS authorization. Pursuant to Section 746.8 of the EAR, all international flights conducted by the aforementioned airline into Russia would have required export or reexport licenses from BIS. Additionally, any domestic Russian flights by the same airline on aircraft reexported to Russia after March 2, 2022 without the required BIS license are also in violation of General Prohibition Ten (GP10). GP10 prohibits continuing with transactions knowing that a violation has occurred or is about to occur.

URAL operated multiple aircraft subject to the EAR, including, but not limited to, on flights into and out of Bishkek, Kyrgyzstan (KG) to Samara, Russia (RU); Dushanbe, Tajikistan (TJ) to Irkutsk, RU; Khudzhand, TJ to Sochi, RU; Tamchy, KG to Moscow, RU; Bishkek, KG to Yekaterinburg, RU; Dushanbe, TJ to Kransnoyarsk, RU; Khudzhand, TJ to Yakaterinburg, RU; Dushanbe, TJ to Mineralyne Vode, RU; Tamchy, KG to Moscow, RU; Dushanbe, TJ to Chelyabinsk, RU; Bishkek, KG to Moscow; RU; Khudzhand, TJ to Moscow, RU; and Bishkek, KG to Moscow, RU. URAL’s website also indicated it intended to continue its domestic and international flight routes.

The issuance of a TDO is one of the most significant civil sanctions under the EAR and is issued by the Assistant Secretary for Export Enforcement to deny the export privileges of a company or individual to prevent an imminent or on-going export control violation. These BIS TDOs were issued under the authority of the Export Control Reform Act of 2018 and 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 as to potential violations of the EAR in the civilian aerospace sector.

The list and additional information on BIS’s actions in response to the Russian invasion is available online here: https://www.bis.gov/russia-belarus_export_controls_resources.

Report suspected export control violations through the BIS online tip portal.  You can also call the Enforcement Hotline at 1-800-424-2980 or email [email protected].

These BIS actions were taken under the authority of the Export Control Reform Act of 2018 and the EAR. For more information, visit www.bis.gov.

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