Foreign Direct Product
Lost at Sea: Lack of BIS Guidance on New Russia/Belarus FDP Rule Creates Compliance Chaos
By: William Klaess, Associate
Date: 04/23/2022
On March 2, 2022, as part of a string of sanctions and export controls, the Russia/Belarus Foreign Direct Product (“FDP”) Rule and Russia/Belarus-Military End User (“MEU”) FDP Rule took effect.1 These rules, generally, restrict the sale to Russia and Belarus of foreign-produced items produced with certain controlled U.S.-origin software or technology.