2022 was his last year of draft eligibility, so he'd be able to sign an ELC once his KHL contract expires.
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Too lazy to dig out the exact CBA clause but in a nutshell it makes a distinction between North American trained players vs. European trained players. If a European player were to spend an entire season in North America (CHL, USHL, NCAA, etc), he'd land in the North American trained bucket.
North American trained
Born January 1 - September 15: draft eligible 3 times
Born September 16 - December 31: draft eligible 2 times
European trained
Born January 1 - September 15: draft eligible 4 times
Born September 16 - December 31: draft eligible 3 times
Some examples:
Brenden Dillon (November 13, 1990) - First time draft eligible in 2009. Undrafted in 2009 and 2010. Signed as undrafted free agent by Dallas in spring 2011.
Andrew Shaw (July 20, 1991) - First time draft eligible in 2009. Undrafted in 2009 and 2010. Drafted in 5th round in 2011.
Sergei Bobrovsky (September 20, 1988) - First time draft eligible in 2007. Undrafted in 2007, 2008, and 2009. Signed by Philadelphia in spring 2010.
Mikko Koskinen (July 18, 1988) - First time draft eligible in 2006. Undrafted in 2006, 2007, and 2008. Drafted in 2nd round in 2009.