Bureau of Industry and Security Bans all Military Sales to China,Russia &Venezuela
Broadens prohibition-exports-to-china-russia-and-venezuela-military-end-users-orition of “military end use” to include any of the elements of “use” (i.e., operation, installation, maintenance, repair, overhaul, or refurbishing), so that the prohibition extends to any item that supports or contributes to the operation or installation or maintenance or repair or overhaul or refurbishing or “development” or “production” of a “military item”; and
Vastly expand the list of items subject to the military end user and end use restrictions, to include many semi-conductors, general purpose electronic equipment, and commercial aircraft parts and components, as well as marine equipment ranging from underwater visions systems to inflatable boats and scuba gear, and information security commodities and software that qualify for mass market treatment (5A992 and 5D992). Requiring military end use and end user checks on exports and reexports of these common commercial items to China, Russia, and Venezuela will present significant new challenges for a wide swathe of companies.
Further, the new rule limits existing exemptions to the Electronic Export Information (EEI) filing requirements such that exporters will need to submit complete EEI filings for nearly every non‑EAR99 export to China, Russia and Venezuela, regardless of value or reason for control (no more $2,500 threshold, and Export Control Classification Numbers (ECCNs) required even if no license is required).