BIS Issues FAQs for Russia, Belarus Savings Clauses

The Bureau of Industry and Security on March 17 issued three frequently asked questions to address matters surrounding the savings clauses in export control rules for Russia and Belarus (see 2202240069 and 2203020072). The FAQs clarify which activities and transactions are captured by the clauses, provide details around the effective dates of the clauses, and clarify whether the clauses would cover an order when the ultimate consignee is a warehouse or distributor.