Would an intra-company transfer of any of the items listed by ECCN in §746.5 or by Schedule B number in Supplement No. 2 to part 746 of the EAR be prohibited if the listed item was being moved within Russia as a transfer (in-country), for one of the restricted uses? Many oilfield services companies have inventory positioned at in-country hubs, and will use the items in inventory for providing services in Russia.

 

The controls set forth in §746.5 cover in-country transfers. If the transaction in Russia also involved a transfer (in-country) as defined in §772.1 of the EAR, then the EAR license requirements and restrictions on the use of license exceptions in §746.5(c) would also apply.  OFAC has also implemented sanctions specific to energy production activities, including those related to providing services for such activities.  Any questions regarding OFAC’s sanctions should be directed to OFAC.

   
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