As discussed in our alert published on Wednesday, February 23, President Biden imposed sanctions targeting Russia's activities in two regions of Ukraine, the Donetsk People's Republic (DNR) and Luhansk People's Republic (LNR) regions. In response to sanctions imposed earlier this week by OFAC, BIS imposed sweeping license requirements for all items subject to the EAR (again, with the exception of food or medicine falling under EAR99, or mass market items unless destined for a Russian government end-user or SoE). Crimea is defined as "land territory in that region as well as any maritime area over which sovereignty, sovereign rights, or jurisdiction is claimed based on occupation of that land territory." The DNR and LNR regions were defined as "the land territory in the DNR and LNR regions, as well as any maritime areas over which sovereignty, sovereign rights, or jurisdiction is claimed based on occupation… or purported sovereignty."