After a year of conflict, is the world anticipating the rebuilding of Ukraine? During the Rebuild Ukraine International Exhibition and Conference in Warsaw, Poland, in February topics included key investment opportunities, recovery and reconstruction. This also included opportunities to sit down with Ukrainian representatives from destroyed communities to discuss opportunities. The next version of this exhibition will take place in Warsaw this November.
All of this got me thinking about the opportunities for Wisconsin’s businesses. Fortunately, Wisconsin’s business development ecosystem is already on top of this issue. The Madison International Trade Association is kicking off a Rebuild Ukraine meeting next week featuring Terry Dittrich*, who participated in the February exhibition in Warsaw.
*This presentation will be repeated later this spring by the District Export Council in case you cannot make the MITA event.
I’m left wondering how will sanctions affect Wisconsin’s businesses from participating in the rebuild.
Current key prohibitions:
- Restrictions on the Export of Services to Russia Executive Order 14071
- Restrictions Regarding Financial Institutions, Financial Transactions, and Related Transactions with Russia
- Specially Designated National and Blocked Person Designations
- Office of Foreign Assets Control, Department of Treasury (OFAC) Restrictions on Doing Business in Ukraine
Fortunately, the U.S. Government wants Wisconsin businesses to participate in the rebuilding of the Ukraine and has, through the issuance of general licenses, authorized certain transactions that would otherwise be prohibited under the RuHSR, Ukraine Sanctions and directives:
- General licenses (GL) authorizing certain activities prohibited under EO 14065
- U.S. Department of Commerce through the Bureau of Industry and Security
- U.S. State Department through their International Traffic in Arms Regulations (ITAR) DDTC
Key Takeaways –
“Know Your Customer” and Screen the following people:
- Customers
- Foreign Sales Agents
- Distributors
- Freight Forwarders
- Potential Foreign Business Partners
- Employees
Actions:
- Verify whether the EAR, ITAR, or both apply to the company’s technologies, software and commodities
- Know the classifications of the company’s products, technology and software
- Conduct sanctioned person screening at the time of the order and prior to the export, reexport or transfer (in-country)
- Verify no party to the transaction is covered by any applicable sanctioned persons list – including the BIS Denied Persons List or Entity List or OFAC’s List of Specially Designated Nationals and Blocked Persons (SDN List)
- Conduct training on how to spot issues
- Know and vet the end-use and end-user, including screening and end-use statements
- Create and enforce policies and procedures
I am eager to help answer questions in the face of uncertainty through my role with the SBDC’s Go Global Initiative, your resource for expanding global markets and understanding trade compliance.
Chris Wojtowicz
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