• Since March the US Commerce and State Departments have suspended their processing of applications seeking a US government license or authorization to export to Russia goods, software, technology or defense-related services.

• On April 28, the Commerce and State Departments modified this partial export embargo on Russia. Going forward, they will only deny applications for export of ‘high-technology’ items or services to Russia or Crimea that could contribute to Russia’s military capabilities.

– This will be based upon a list, to be developed within the US government, of items and services that could make such a contribution.

• While this apparently means that processing will restart for license applications to export to Russia items and services that would not contribute to the Russian military, significant delays can be expected in processing such applications.

• While this apparently means that processing will restart for license applications to export to Russia items and services that would not contribute to the Russian military, significant delays can be expected in processing such applications.