Export Compliance Russia Issues Over Ukraine

Export Compliance Russia – $150 Billion orbiting ISS lab divided on Cold War lines.

ITAR Export Compliance Russia in Space with the ISS
ISS Photo courtesy of NASA

No one thought about Export Compliance Russia Issues during the Cold War in the fifties, sixties and seventies.  But, In 1975, the U.S. and Russia (USSR), even with the political and global issues were able to organize the Apollo – Soyuz docking mission in orbit where astronauts and cosmonauts posed for pictures as they shook hands through an air lock.  Export Compliance Russia wasn’t an issue in 1975, the Arms Export Control Act was signed into law by President Ford in 1976!

And the two countries have worked together with a global group of countries including Japan, Canada, United Kingdom and France, to build the International Space Station (ISS).  But now that spirit of cooperation is in dramatic decline.    The regulations are known as ITAR or International Traffic in Arms Regulations.  Export Compliance Russia rules on what can be “disclosed to foreign persons” have turned what was peaceful cooperation on the ISS into a ITAR Export Compliance nightmare.

In April a memo from Michael F. O’Brien was leaked indicating a “suspension of NASA contact with Russian entities” with new Export Compliance Russia restrictions on “high technology defence articles or services” confirming the US government’s intent to punish Russia’s space industry.

Here is the text of that memo:

From: O’Brien, Michael F (HQ-TA000)
Sent: Wednesday, April 02, 2014 9:33 AM
To: [Deleted]
Cc:  [Deleted]

Subject: Suspension of NASA contact with Russian entities

Dear Colleagues,

Given Russia’s ongoing violation of Ukraine’s sovereignty and territorial integrity, until further notice, the U.S. Government has determined that all NASA contacts with Russian Government representatives are suspended, unless the activity has been specifically excepted.  This suspension includes NASA travel to Russia and visits by Russian Government representatives to NASA facilities, bilateral meetings, email, and teleconferences or videoconferences.  At the present time, only operational International Space Station activities have been excepted.  In addition, multilateral meetings held outside of Russia that may include Russian participation are not precluded under the present guidance.  If desired, our office will assist in communication with Russian entities regarding this suspension of activities.  Specific questions regarding the implementation of this guidance can be directed to Ms. Meredith McKay, 202.358.1240, in our office.

We remain in close contact with the Department of State and other U.S. Government departments and agencies.  If the situation changes, further guidance will be disseminated.


Michael F. O’Brien

Associate Administrator for International and Interagency Relations

National Aeronautics and Space Administration

There is still an issue with Roscosmos, Russia’s space agency, it is the sole provider of transportation for U.S. Astronauts.  With the Space Shuttle no longer available since 2011, the U.S. is completely reliant on Roscosmos allowing U.S. Astronauts rides on Soyuz rockets.  Russia still uses the same Soyuz platform very similar to the one used in 1975’s Apollo-Soyuz Mission.

Last week, Russia’s Deputy Prime Minister, Dmitry Rogozin, said that Moscow was “very concerned about continuing to develop hi-tech projects with such an unreliable partner as the United States”, and stated his country would reject NASA’s plan to use the ISS beyond the station’s planned 2020 decommission.

The U.S. pays Russia $71m per astronaut ride to the ISS and the Pentagon relies solely on Russian RD-180 rockets for its launches as a second stage.  The U.S. has enough stock for two years, but will not be of use if Roscosmos continues to sell engines under the new ITAR Export Compliance restrictions.  They will not be used to launch military satellites but strictly commercial launches.

NASA’s chief executive Charles Bolden used the threat of limited launches to try to  force Congress to accept the President’s proposed $17.5B budget for 2015. This includes $848M for the agency’s “Commercial Crew” system.

“The choice moving forward is between fully funding the President’s request to bring space launches back to American soil or continuing to send millions to the Russians,” Mr. Bolden wrote in a March blog post. “It’s that simple.”s.

Clearly ITAR Export Compliance Regulations are applicable anywhere on Earth and orbiting ITAR Export Compliance now must be applied by U.S. Astronauts on the ISS.

Kevin Gholston

Kevin Gholston

Subject Matter Expert in MIL-STD-810, ITAR & Export-Compliance and Quality including ISO9001:2015, AS9100D and AAR M-1003

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