Imposition of Sanctions on ‘Luxury Goods’ Destined for Russia and Belarus and for Russian and Belarusian Oligarchs and Malign Actors Under the Export Administration Regulations (EAR)

On March 11, 2022, In response to the Russian Federation’s (Russia’s) further invasion of Ukraine, and Belarus’s substantial enabling of Russia’s invasion, the Department of Commerce Belarus of ‘luxury goods’ under the Export Administration Regulations (EAR) and for exports, reexports and transfers (in-country) worldwide to certain Russian or Belarusian oligarchs and other malign actors supporting the Russian or Belarusian governments. Taken together, these new export controls will significantly limit financially elite individuals’ and organizations’ access to luxury goods and thereby accentuate the consequences of providing such support.

The Rule is scheduled to be published in the Federal Register on March 16, 2022. A pre-publication version is available HERE.