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

Tuesday, February 23, 2016
Sandler, Travis & Rosenberg Trade Report

The Bureau of Industry and Security has issued a final rule that, effective Feb. 23, adds eight persons in the United Arab Emirates to the list of entities restricted from receiving exports of dual-use goods from the United States. BIS has determined that four of these entities have made attempts to supply U.S.-origin items to persons designated as foreign terrorist organizations and present a risk of supplying additional items to embargoed destinations without the required authorizations. BIS states that there is reasonable cause to believe that the other four entities prevented the successful accomplishment of end-use checks by BIS officials.

For these eight 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 nine entities in Ireland and the UAE from the Entity List and modifies six existing entries (from Iran, Armenia, Greece, India, Pakistan and the United Kingdom), one to correct the Federal Register citation and the rest to reflect the removal of a UAE entity.

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 Feb. 23 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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