The U.S. Department of Commerce's Bureau of Industry and Security (BIS) has renewed a Temporary Denial Order (TDO) against Siberian Airlines, doing business as S7 Airlines, for one year, effective immediately upon issuance on December 8, 2025. This order, signed by Assistant Secretary of Commerce for Export Enforcement David Peters, denies the Russian airline export privileges under the Export Administration Regulations (EAR) to prevent imminent violations. The renewal addresses S7 Airlines' pattern of operating U.S.-origin aircraft on flights into, out of, and within Russia without required licenses, in defiance of controls implemented following Russia's February 2022 invasion of Ukraine. This development underscores the U.S. government's commitment to restricting Russia's access to sensitive technologies amid ongoing geopolitical tensions, potentially affecting international aviation and trade compliance.
Background on U.S. Export Controls and Russia's Invasion
In response to Russia's further invasion of Ukraine in February 2022, BIS introduced stringent export controls targeting Russia's defense, aerospace, and maritime sectors. These measures aim to limit Russia's access to technologies essential for its military capabilities. Effective February 24, 2022, BIS imposed license requirements for exporting, reexporting, or transferring aviation-related items classified under Export Control Classification Number (ECCN) 9A991 to Russia. License applications for such items face a policy of denial.
Additionally, as of March 2, 2022, BIS revoked eligibility for the Aircraft, Vessels, and Spacecraft (AVS) license exception for any aircraft registered in, owned, controlled, chartered, or leased by Russia or Russian nationals. This means U.S.-origin aircraft or foreign aircraft with more than 25% controlled U.S.-origin content require a license to travel to Russia. These controls, authorized under the Export Control Reform Act of 2018 (ECRA) and building on prior frameworks like the International Emergency Economic Powers Act (IEEPA), reflect a broader strategy to atrophy Russia's industrial base and curb its global influence.
S7 Airlines, based in Novosibirsk, Russia, operates a fleet that includes Boeing 737 aircraft subject to these EAR provisions due to their U.S.-origin components. The airline's activities have repeatedly clashed with these restrictions, leading to enforcement actions.
Procedural History of the Temporary Denial Order
The initial TDO against S7 Airlines was issued ex parte on June 24, 2022, by the then-Assistant Secretary for Export Enforcement, denying export privileges for 180 days to avert imminent violations. This order was published in the Federal Register on June 29, 2022. Subsequent renewals extended the TDO: on December 20, 2022 (published December 23, 2022), June 15, 2023 (published June 21, 2023), December 11, 2023 (published December 14, 2023), and December 6, 2024 (published December 13, 2024).
The latest renewal request, submitted by BIS's Office of Export Enforcement (OEE) on November 5, 2025, was filed more than 20 days before the prior order's expiration, in line with EAR Section 766.24(d). Due to suspended mail service to Russia, OEE attempted alternative delivery methods. No opposition was received from S7 Airlines. The renewal extends the TDO for one year, a duration permitted under recent amendments allowing extended periods for patterns of repeated violations (88 FR 59791, August 30, 2023).
Basis for Renewal and Evidence of Violations
BIS justified the renewal by demonstrating S7 Airlines' ongoing disregard for U.S. export controls, based on evidence of deliberate and significant violations. The legal standard under EAR Section 766.24 requires showing that the order prevents an 'imminent violation,' which can include a likelihood of future breaches if past actions were significant, deliberate, and likely to recur.
Initial violations cited in the 2022 TDO involved S7 Airlines operating EAR-subject Boeing 737-8LP aircraft (ECCN 9A991.b) on international flights into Russia from locations like Atyrau, Kazakhstan, Bishkek, Kyrgyzstan, and Urgench, Uzbekistan after March 2, 2022, without BIS authorization. Domestic flights within Russia also violated EAR Section 736.2(b)(10).
Subsequent renewals documented continued operations. For instance, the December 2022 order noted flights from Bangkok, Thailand, Antalya, Türkiye, and Urgench, Uzbekistan. The June 2023 order cited routes from Istanbul, Türkiye, Beijing, China, and Bangkok. The December 2023 order included flights from Bangkok, Fergana, Uzbekistan, and Istanbul. The December 2024 order detailed operations from Bangkok, Beijing, and Istanbul.
The current renewal provides fresh evidence of violations post-December 2024, including flights in October 2025. Publicly available flight tracking data shows aircraft with serial numbers 41709, 41710, and 41707 operating routes such as Istanbul to Novosibirsk on October 18, 2025, Dubai to Novosibirsk on October 22, 2025, and Rayong Pattaya, Thailand to Irkutsk on October 9, 2025. These activities violate both the EAR and prior TDOs, as engaging in prohibited conduct under a denial order constitutes a separate infraction (15 CFR 764.2(a) and (k)).
Assistant Secretary Peters found these violations 'significant and deliberate,' with a high likelihood of continuation, warranting the one-year extension to protect public interest and notify global entities to avoid dealings with S7 Airlines involving EAR-subject items.
Scope and Implications of the Renewed Order
The renewed TDO prohibits S7 Airlines and its agents from participating in transactions involving EAR-subject items, except for safety-of-flight activities authorized by BIS under Section 764.3(a)(2). This includes bans on applying for licenses, negotiating deals, or benefiting from exports. Third parties are barred from exporting to or servicing items for S7 Airlines without authorization.
Related entities could face similar restrictions under EAR Section 766.23 after notice and comment. S7 Airlines may appeal to the Administrative Law Judge or oppose future renewals.
From a broader perspective, this action highlights tensions in international aviation amid sanctions. Proponents view it as essential for enforcing export controls and deterring evasion, while critics, including Russian officials, argue it disrupts global trade and aviation safety. Legal precedents like ECRA emphasize the U.S.'s authority to impose such measures during national security concerns.
Short-term implications include operational challenges for S7 Airlines, potential rerouting of flights, and heightened compliance burdens for international partners. Long-term effects could involve shifts in global supply chains for aircraft parts and increased scrutiny on Russian carriers.
In summary, the renewal reflects BIS's sustained enforcement against export violations tied to Russia's actions in Ukraine. Potential next steps include further investigations, possible permanent denial orders, or diplomatic negotiations affecting U.S.-Russia relations. Ongoing debates center on balancing national security with international commerce, with challenges in monitoring compliance amid geopolitical strains.
