On 29 January, the Commerce Department’s Bureau of Industry and Security (“BIS”) amended its Export Administration Regulations (“EAR”) to require a license for the export or reexport to eastern Ukraine of any item subject to the EAR, other than food and medicine designated as EAR99.  Simultaneously, the  BIS established a presumption of denial for all such export and reexport license applications with an exception for items authorised under Ukraine-Related General Licence No. 4 of the Treasury Deparment’s Office of Foreign Assets Control (“OFAC”), which applies to certain exports of agricultural commodities, medicine, medical supplies and replacement parts for certain medical equipment.  The BIS stated that this action is consistent with the goals and objectives of Executive Order (E.O.) 13685, which implemented a trade ban between the United States and eastern Ukraine (see our Client Update of 8 January 2015).