Law360, New York (August 13, 2014, 11:08 AM EDT) -- As the situation in Ukraine has escalated, the U.S. has expanded economic sanctions against Russia and begun targeting key Russian sectors, including energy. These sanctions have included not only action by the U.S. Department of the Treasury, but also restrictions by the U.S. export control agencies on exports to these critical Russian sectors. On Aug. 6, 2014, the U.S. Department of Commerce's Bureau of Industry and Security published a final rule[1] implementing a new restrictive licensing policy for exports, reexports and in-country transfers of certain dual-use items that will be used for oil or gas exploration or production in Russian deepwater, Arctic offshore or shale projects. This policy is intended to impede Russia's development of challenging energy projects, which are key to its economy. However, the rule will also significantly affect U.S. exporters and producers of these products used for oil and gas exploration or production....