Ukraine Crisis: Ural Airlines Stripped Of Export Privileges

Anna Zvereva from Tallinn, Estonia, CC BY-SA 2.0 , via Wikimedia Commons

LONDON – The U.S Bureau of Industry & Security (BIS) has issued an order stripping Russian carrier Ural Airlines of export privileges pertinent to the United States.

This comes as a specific part of sanctions against Russia in the wake of the Ukraine Crisis.

TDO’s Issued on Ural…

A Temporary Denial Order (TDO) has been issued on the airline that terminates the right to participate in transactions subject to the Export Administration Regulations (EAR), which is pertinent to exports and reexports from the United States.

It is understood that this TDO is in place for 180 days and can be renewed at any time.

Commenting on this order was the Assistant Secretary of Commerce for Export Enforcement, Matthew Axelrod:

“This Temporary Denial Order marks the tenth TDO issued against Russia and Belarus’s biggest airlines since Russia’s brutal invasion of Ukraine”.

“Today’s action highlights the peril and consequences of attempting to circumvent our comprehensive export controls and further impairs Russia’s aviation sector.”

BIS Adds to Axelrod’s Words…

The BIS has also added its own form of statement to add to Axelrod’s words:

“The severe restriction in export privileges of these companies is a reminder to parties in Russia, as well as throughout the rest of the world, that U.S. legal authorities are substantial, far-reaching, and have a meaningful impact on access to global commerce by parties found to be in violation of U.S. law.”

How Did Ural Break This Rule?

The order also went into how Ural Airlines broke the export privileges:

“URAL has engaged in and continues to engage in recent conduct prohibited by the EAR by operating controlled aircraft subject to the EAR without the required BIS authorization.”

“Pursuant to Section 746.8 of the EAR, all international flights conducted by the aforementioned airline into Russia would have required export or reexport licenses from BIS.”

“Additionally, any domestic Russian flights by the same airline on aircraft reexported to Russia after March 2, 2022, without the required BIS license are also in violation of General Prohibition Ten (GP10). GP10 prohibits continuing with transactions knowing that a violation has occurred or is about to occur.”

“URAL operated multiple aircraft subject to the EAR, including, but not limited to, on flights into and out of Bishkek, Kyrgyzstan (KG) to Samara, Russia (RU); Dushanbe, Tajikistan (TJ) to Irkutsk, RU; Khudzhand, TJ to Sochi, RU; Tamchy, KG to Moscow, RU; Bishkek, KG to Yekaterinburg, RU; Dushanbe, TJ to Krasnoyarsk, RU; Khudzhand, TJ to Yekaterinburg, RU; Dushanbe, TJ to Mineralyne Vode, RU; Tamchy, KG to Moscow, RU; Dushanbe, TJ to Chelyabinsk, RU; Bishkek, KG to Moscow; RU; Khudzhand, TJ to Moscow, RU; and Bishkek,
KG to Moscow, RU.”

“URAL’s website also indicated it intended to continue its domestic and international flight routes.”

“The issuance of a TDO is one of the most significant civil sanctions under the EAR and is issued by the Assistant Secretary for Export Enforcement to deny the export privileges of a company or individual to prevent an imminent or ongoing export control violation.”

“These BIS TDOs were issued under the authority of the Export Control Reform Act of 2018 and the EAR.”


It remains clear that the pressure points continue on Russian infrastructure, especially with airlines and aviation bringing in a big chunk of money to Russian GDP.

The Commerce Department in the United States has been continuing its TDO usage more and more as this crisis continues, with probably many more rulings to be made in the future.

But for now, we shall wait and see what happens on the Ural Airlines side.

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