This July, the U.S. Department of Commerce (“Commerce” or “the Department”) added several European surveillance firms plying commercial spyware to its export control list. The firms at issue are Cytrox, which is based in Hungary, and Intellexa, which has Greek origins. Two associated companies from Macedonia and Ireland have also been added to the export control list.

These additions are only the newest on Commerce’s list. The Department made several other important additions to rules that went effective on May 19:

• Concerning industrial items, including 1224 new products, will now require a license for export, re-export, and transfer to or within Russia or Belarus. These items include various electronics, instruments, agricultural machinery, and advanced fibers to reinforce composite materials, such as carbon fibers. That being said, the Department’s Bureau of Industry and Security (BIS) “will generally review license applications for certain items that are predominantly agricultural or medical in nature on a case-by-case basis.”
• Chemicals such as lithium chloride (CAS 7447-41-8), lithium chloride hydrate (CAS 85144-11-2), lithium chloride monohydrate (CAS 16712-20-2), and lithium carbonate (CAS 554-13-2) will now be controlled.
• A license is now required for HTS-6 Code 8548.00 (Electrical Parts of Machinery or Apparatus, NESOI) when destined eventually for Iran, Russia, or Belarus.
• There are expanded restrictions attending the Foreign-Direct Product (FDP) Rule to cover the Russian-occupied Crimea region of Ukraine.
• There were additions to its Entity List, including 71 Russian, Armenian, and Kyrgyz entities used for supplying assistance to the Russian military and defense.

These Entity List additions and export controls supplement the U.S. Government’s set of export controls, sanctions, and import restrictions imposed since Russia invaded Ukraine in early 2022. On a related level, the Office of Foreign Assets Control (OFAC) of the U.S. Department of the Treasury has sanctioned more than 300 Russian entities and those associated with them in assisting Russian military endeavors against Ukraine.