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Restrictions on Exports of EAR-Regulated Goods Added, Revised

Friday, May 26, 2017
Sandler, Travis & Rosenberg Trade Report

The Bureau of Industry and Security has issued a final rule adding 11 persons in Pakistan, three in Turkey, and two in the United Arab Emirates to the list of entities restricted from receiving U.S. exports of goods controlled under the Export Administration Regulations. This rule also modifies two Entity List entries under the destinations of China and Hong Kong.

BIS has determined that nine of the 11 Pakistani entities are government, parastatal, and private entities involved in activities contrary to U.S. national security and foreign policy interests and that another appears to be acting and procuring items on behalf of another entity added to the Entity List in November 1998. In addition, one Pakistani entity and two in the UAE are being added for supplying U.S.-origin items without the necessary licenses to a Pakistani entity added to the Entity List in September 2014. The three Turkish entities are being added on the basis of their involvement in the reexportation to Iran of U.S.-origin metal alloy powders with aerospace, missile, and nuclear applications.

For these 16 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.

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 26 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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