Practice Areas
Nine Added to List of Entities Restricted from Receiving Exports of Dual-Use Goods
The Bureau of Industry and Security has issued a final rule that, effective May 1, adds eight Chinese companies and one Chinese individual to the Entity List for supplying Iran’s ballistic missile program through a Chinese proliferator.
For one of these persons, BIS is imposing a license requirement for all items subject to the Export Administration Regulations and establishing a license application review policy of presumption of approval for EAR99 items and case-by-case review for all items on the Commerce Control List. For the other eight persons, BIS is imposing a license requirement for all items subject to the EAR and a license review policy of presumption of denial. These license requirements apply to any transaction in which items are to be exported, reexported or transferred (in-country) to any of persons being added to the Entity List or in which such persons 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 such 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 May 1 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.
