BIS Medical-Related Licensing Guidance May Not Always Be Easy to Follow, Law Firm Says
The Bureau of Industry and Security's recently issued guidance for medical-related export license applications (see 2307210019) is a “welcome development” and should be reviewed by exporters submitting applications for medical items to Russia, Belarus and certain regions of Ukraine, Baker McKenzie said July 19. But the firm also said exporters may not always be able to meet all the criteria outlined in the guidance, which offers best practices for the type of information applications should include, such as end-use or end-user statements, a narrow transaction scope and specific descriptions of the items.
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The “realities of commercial transactions and medical supply chains may not always lend themselves to easily following this guidance,” Baker McKenzie said. “This underscores the importance of clearly explaining those realities in license applications, often in an accompanying letter of explanation.” The firm noted that the guidance doesn’t outline “requirements for applications,” but is instead “styled as ‘best practices’ that applicants are ‘encouraged’ to follow.”