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On August 6, 2014, the Bureau of Industry and Security (BIS) published new export controls that impact oilfield products being exported or reexported to Russia. These controls are similar to those the European Union (EU) passed on August 1, 2014.
The list of items that are being controlled for export include, but are not limited to, drilling rigs, parts for horizontal drilling, drilling and completion equipment, subsea processing equipment, Arctic-capable marine equipment, wireline and down hole motors and equipment, drill pipe and casing, software for hydraulic fracturing, fracking fluids, high pressure pumps, seismic acquisition equipment, remotely operated vehicles, compressors, expanders, valves and risers.
The Federal Register notice makes it clear that seismic “data does not come within the definition of ‘technology,’” but it is being controlled as a commodity under new Export Control Classification Number, ECCN 0A998. Under this rule exporting analyzed seismic data to Russia now requires a license from BIS.
The new regulations also prohibit the export of commercial charges and devices containing energetic materials, firing sets, and detonators used in the oil patch.
Click here to view a copy of the new regulation.
For more information on the matters discussed in this Locke Lord QuickStudy, please contact the author.