Today, the Bureau of Industry and Security (BIS) imposed military end use and end user licensing requirements on exports to Venezuela. This new restriction parallels the existing restrictions in place regarding China (for military end uses) and Russia (for both military end uses and end users). It prohibits unlicensed exports to Venezuela of certain items subject to the EAR that the exporter knows are destined for military end users or end uses, as those terms are defined in the rule.
For exporters, this change reinforces the importance of knowing the EAR’s end use and end user restrictions and conducting effective due diligence on customers and other parties to export transactions.
Unlike similar changes of this type, BIS gave exporters a bit of a break by not making the restriction retroactive to contracts signed prior to November 7, 2014.
For more information, the full Federal Register notice is available here.
