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Exports of Dual-Use Goods Restricted to Ten Foreign Entities

Tuesday, July 28, 2015
Sandler, Travis & Rosenberg Trade Report

The Bureau of Industry and Security has issued a final rule that, effective July 28, adds ten persons to, and removes four persons from, its list of entities restricted from receiving exports of dual-use goods from the United States.

BIS is adding eight individuals and companies from China that it has reasonable cause to believe have illicitly procured sensitive U.S. items for unauthorized end use in China and Iran. BIS is also adding one company and one individual from South Korea that it has reasonable cause to believe have supported the illicit procurement efforts of ballistic-missile related parties in Iran since at least 2011.

For those being added to the Entity List there will be a license requirement for exports of all items subject to the Export Administration Regulations and a license review policy of presumption of denial. The license requirements apply to any transaction in which items are to be exported, reexported or transferred (in-country) to any of these persons or in which they 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 these persons.

Shipments of items removed from eligibility for a license exception or export or reexport without a license (NLR) as a result of these additions that were en route aboard a carrier to a port of export or reexport on July 28 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.

This rule also removes from the Entity List Shanghai Hengtong Optics Technology Limited in China and Zener Electrical & Electronics, Zener Electronics Services and Zener Navcom in the United Arab Emirates. This removal eliminates the existing license requirements in Supplement No. 4 to part 744 for exports, reexports and transfers (in-country) to these entities but does not relieve persons of other obligations under part 744 or other parts of the EAR.

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