BIS Designates Entity Listed Wagner Group as Russian Military End-User

The Bureau of Industry and Security this week announced new, stricter license requirements for exports to the Wagner Group, a Russian private military company, by designating it as a Russian military end-user, BIS said in a final rule effective Dec. 21. The new designation imposes a license review policy of denial for all items subject to the Export Administration Regulations, except for certain food and medicine, which will be reviewed on a case-by-case basis.

The new designation will place “additional severe restrictions on the Wagner Group’s ability to acquire items globally to support the Russian government’s unprovoked war in Ukraine” and ensure that the “license requirements apply to Wagner Group wherever located worldwide,” BIS said. It also subjects the Wagner Group, which is on the Entity List, to license requirements under the Russia/Belarus Military End User Foreign Direct Product Rule.

The move sends “a clear message to non-state actors seeking to pick up the baton of brutality from [Russian President Vladimir] Putin’s faltering military that the Department of Commerce will not hesitate to act against them,” BIS Undersecretary Alan Estevez said. Thea Kendler, the agency’s assistant secretary for export administration, said the military end-user designation makes “crystal clear which entities are a threat to Ukraine and need to be denied access to our technologies.”

All exports that now require a license as a result of the changes that were aboard a carrier to a port as of Dec. 21 may proceed to their destinations under the previous eligibility, BIS said. BIS also added one address and two additional aliases to the Wagner Group’s entry.