On September 2, 2015, the US Government announced the imposition of measures including the following against Rosoboronexport (ROE) (Russia) and any successor, sub-unit, or subsidiary thereof: “No department or agency of the United States Government may procure or enter into any contract for the procurement of any goods, technology, or services from [Rosoboronexport (ROE) (Russia) and any successor, sub-unit, or subsidiary thereof], except to the extent that the Secretary of State otherwise may determine . . . .”

In a Federal Register notice issued today, the US Government decided to modify the measure described above against ROE and any successor, sub-unit, or subsidiary. Specifically, the US Government decided that sanctions set forth above shall not apply to subcontracts at any tier with ROE and any successor, sub-unit, or subsidiary thereof made on behalf of the US Government for goods, technology, and services for the maintenance, repair, overhaul, or sustainment of Mi-17 helicopters for the purpose of providing assistance to the security forces of Afghanistan, as well as for the purpose of combating terrorism and violent extremism globally. 

Such subcontracts include the purchase of spare parts, supplies, and related services for these purposes. The notice indicates that the partial removal of sanctions applies retroactively as of the effective date of the sanctions, and will remain in place for two years from that date, except to the extent that the Secretary of State may otherwise determine.

Today’s Federal Register notice states that the modification does not apply to any other measures imposed pursuant to the INKSNA and announced in Public Notice 9251 published on September 2, 2015.