On June 29, 2020, the new military end use/end user rule for China, Russia, and Venezuela in Section 744.21 of the Export Administration Regulations (EAR) went into effect. (Please see here for our prior post detailing changes to Section 744.21.) In connection with this new rule, the Department of Commerce’s Bureau of Industry and Security, published 32 Frequently Asked Questions that detail the changes to Section 744.21, give interpretations of key terms, and provide guidance on various scenarios. These FAQs provide helpful guidance for companies involved in exports to China, Russia, and Venezuela of items that are classified under an Export Control Classification Number that is subject to Section 744.21.
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