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Exports of Dual-Use Goods Restricted to 11 Entities in China, Pakistan and UAE

Wednesday, February 18, 2015
Sandler, Travis & Rosenberg Trade Report

The Bureau of Industry and Security has issued a final rule that, effective Feb. 18, revises its list of entities restricted from receiving exports of dual-use goods from the United States.

Additions. This rule adds to the Entity List (a) four entities in China for using U.S.-origin items to produce supercomputers believed to be used in nuclear explosive activities and (b) four entities in Pakistan and three in the United Arab Emirates for engaging in activities in support of a designated foreign terrorist organization and a number of transnational extremist organizations.

For the four Chinese entities there will be a license requirement for all items subject to the Export Administration Regulations and a license application review policy of case-by-case review. For the other seven entities there will be a license requirement for all items subject to the EAR 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 entities or in which such entities 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 these additions that were en route aboard a carrier to a port of export or reexport on Feb. 18 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.

Removal. This rule also removes SATCO GmbH aka Satco Inc., located in Germany, from the Entity List based on a request from an unrelated company of the same name being adversely impacted, the fact that SATCO GmbH is not a legally established corporate entity in Bremen, Germany, and the lack of evidence of the use of this name by a particular procurement ring that coordinated the supply and sale of U.S.-origin items in violation of U.S. regulations. This removal eliminates the existing license requirements in Supplement No. 4 to part 744 for exports, reexports and transfers (in-country) to this entity.

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