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Restrictions on Exports of EAR-Regulated Goods Added, Revised, Removed

Thursday, March 22, 2018
Sandler, Travis & Rosenberg Trade Report

The Bureau of Industry and Security has issued a final rule that, effective March 22, adds fifteen entities in South Sudan, seven entities in Pakistan, and one entity in Singapore to the Entity List, which lists entities restricted from receiving U.S. exports of goods controlled under the Export Administration Regulations. This rule also (a) removes one entity from Ecuador and one entity from the United Arab Emirates and (b) corrects the license requirement for 12 entities from Russia added to the Entity List previously.

BIS is adding the fifteen entities in South Sudan because they are government, parastatal, and private entities involved in activities contrary to U.S. foreign policy interests, an entity in Singapore and an entity in Pakistan for procuring items for several Pakistani entities on the Entity List, one entity in Pakistan for procuring U.S.-origin items on behalf of nuclear-related entities in Pakistan on the Entity list, three entities in Pakistan involved in the proliferation of unsafeguarded nuclear activities, one entity in Pakistan obtaining items subject to the EAR on behalf of listed entities without the required licenses, and one entity in Pakistan for supplying a Pakistani nuclear-related entity on the Entity List.

For these 23 entities there is a license requirement for exports, reexports, or transfers (in-country) of 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.

The removal of the two entities eliminates the existing license requirements in supplement no. 4 to part 744 for exports, reexports, and transfers (in-country) to these entities, though other applicable regulatory provisions remain in effect.

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