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Exports of EAR-Regulated Goods to Ten Foreign Entities Restricted

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

The Bureau of Industry and Security has issued a final rule adding 10 persons under 14 entries in Iraq, the Philippines, Syria and Turkey to the list of entities restricted from receiving U.S. exports of goods controlled under the Export Administration Regulations. BIS has determined that nine of these entities have been providing logistical and material support to the Islamic State of Iraq and the Levant and that the other was indicted for exporting defense articles to the Philippines in violation of the EAR and the International Traffic in Arms Regulations.

For these ten 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 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 Aug. 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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