Embargo on Covered Regions of Ukraine
The embargo and controls that were previously in place for the Crimea region of Ukraine now also apply to the DNR and LNR and require a license to export, reexport, or transfer within the three territories of any items subject to the EAR, other than food and medicine designated as EAR99, or “software necessary to enable the exchange of personal communications over the Internet.” License applications will be reviewed with a policy of denial, except applications for transactions authorized under OFAC Ukraine-Related General Licenses. BIS also limited the license exceptions available for DNR and LNR to the same license exceptions that were previously available to the Crimea Region of Ukraine.