This Guidance does not create any privileges, benefits, or rights, substantive or procedural, enforceable by any individual, organization, party, or witness in any administrative, civil, or criminal matter.



If the item is not listed in EAR §746.5 by ECCN or in  Supplement No. 2 to Part 746 –“Russian Industry Sector Sanctions List” - by Schedule B number, then the sanctions  do not impose any additional license requirements or exclusions on the use of EAR license exceptions. However, in making any license determination, the full scope of EAR license requirements needs to be taken into account before making a No License Required (NLR) determination, including license requirements in Part 744 of the EAR.

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