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Restrictions on Exports of Dual-Use Goods to Foreign Entities Modified

Wednesday, November 11, 2015
Sandler, Travis & Rosenberg Trade Report

The Bureau of Industry and Security has issued a final rule that, effective Nov. 12, adds seven entities in China and Hong Kong to its list of entities restricted from receiving exports of dual-use goods from the United States. BIS has determined that these entities have made attempts to supply U.S.-origin items to an Iranian party associated with the Iranian defense ministry and an Iranian party whose customers include companies designated as specially designated nationals.

For these seven 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.

This rule also removes two persons from the Entity List and modifies ten existing entries (one under China and nine under Hong Kong) to provide additional or modified addresses and/or aliases for these persons.

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 Nov. 12 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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