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Restrictions on Exports of EAR-Regulated Goods Added, Revised

Monday, June 24, 2019
Sandler, Travis & Rosenberg Trade Report

The Bureau of Industry and Security has issued a final rule that, effective June 24, adds five entities under the destination of China to the Entity List, which lists entities restricted from receiving U.S. exports of goods controlled under the Export Administration Regulations. This rule also modifies the listing for one entity under the destination of China.

The new entries consist of the following five Chinese entities for which BIS has reasonable cause to believe, based on specific and articulable facts, that they have been involved, are involved, or pose a significant risk of being or becoming involved in activities that are contrary to the national security or foreign policy interests of the U.S.

- Chengdu Haiguang Integrated Circuit, including two aliases (Hygon and Chengdu Haiguang Jincheng Dianlu Sheji)

- Chengdu Haiguang Microelectronics Technology, including two aliases (HMC and Chengdu Haiguang Wei Dianzi Jishu)

- Higon, including five aliases (Higon Information Technology, Haiguang Xinxi Jishu Youxian Gongsi, THATIC, Tianjing Haiguang Advanced Technology Investment, and Tianjing Haiguang Xianjin Jishu Touzi Youxian Gongsi)

- Sugon, including nine aliases (Dawning, Dawning Information Industry, Sugon Information Industry, Shuguang, Shuguang Information Industry, Zhongke Dawn, Zhongke Shuguang, Dawning Company, and Tianjin Shuguang Computer Industry)

- Wuxi Jiangnan Institute of Computing Technology, including two aliases (Jiangnan Institute of Computing Technology and JICT)

BIS is also modifying the existing entry for National University of Defense Technology (NUDT) to add one alias (Hunan Guofang Keji University) and four locations.

For these entities, BIS is imposing a license requirement for exports of all items subject to the EAR and a license review policy of presumption of denial. This 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 license exception eligibility or for 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 June 24 pursuant to actual orders for export or reexport to a foreign destination may proceed to that destination under the previous license exception eligibility or without a license.

For more information on restrictions on exports to persons on the Entity List or other lists, please contact export attorney Kristine Pirnia at (202) 730-4964.

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