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Export Restrictions Added for Syrian Entities, Removed for Singapore and Taiwan Entities

Monday, December 19, 2011
Sandler, Travis & Rosenberg Trade Report

The Bureau of Industry and Security has issued a final rule that, effective Dec. 16, makes several changes to the Entity List. First, BIS is adding two persons under the United Arab Emirates based on evidence that they purchased U.S.-origin Internet filtering devices and transshipped them to Syria, where they may have been used by the Syrian government to block pro-democracy Web sites and identify pro-democracy activists as part of a crackdown against the Syrian people. Second, on the basis of the annual review by the End-User Review Committee, this rule amends the Entity List by removing two persons located in Singapore, removing two persons located in Taiwan and revising the entry for one person located in Malaysia.

For persons on the Entity List there is an export license requirement for all items subject to the Export Administration Regulation and a license application review policy of a presumption of denial. The license requirement applies to any transaction in which items are to be exported, reexported or transferred (in-country) to such persons or in which such persons act as purchaser, intermediate consignee, ultimate consignee or end-user. In addition, no license exceptions are available for exports, reexports or transfers (in-country) to persons on the Entity List.

Shipments of items removed from eligibility for a license exception or export or reexport without a license (NLR) as a result of this rule that were on dock for loading, on lighter, laden aboard an exporting or reexporting carrier, or en route aboard a carrier to a port of export or reexport on Dec. 16 pursuant to actual orders for export or reexport to a foreign destination may proceed to that destination under the previous eligibility for a license exception or NLR so long as they are exported or reexported before Jan. 3, 2012. Any such items not actually exported or reexported before midnight on Jan. 3 will require a license in accordance with the EAR.

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