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Exports of Dual-Use Goods to Four Foreign Entities Restricted

Wednesday, March 09, 2016
Sandler, Travis & Rosenberg Trade Report

The Bureau of Industry and Security has issued a final rule that, effective March 8, adds three entities in China and one in Iran to the list of entities restricted from receiving exports of dual-use goods from the United States. BIS has determined that one of the Chinese entities planned and organized a scheme to establish, control and use a series of shell companies to illicitly reexport controlled items to Iran and that the other three entities were involved in this scheme.

For these entities there will be a license requirement for all items subject to the Export Administration Regulations and a license review policy of presumption of denial. The license requirement applies to any transaction in which items are to be exported, reexported or transferred (in-country) to any of these entities 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 entities.

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 en route aboard a carrier to a port of export or reexport on March 8 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.

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