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Exports Restricted to 50 Persons Added to Unverified List

Thursday, April 11, 2019
Sandler, Travis & Rosenberg Trade Report

The Bureau of Industry and Security has issued a final rule that, effective April 11, adds 50 foreign persons to the Unverified List because an end-use check could not be completed satisfactorily for reasons outside the U.S. government’s control. BIS is also removing five persons in Russia, three in China, one in Finland, and one in the United Arab Emirates from the Unverified List.

The new entries consist of 37 persons in China, six in Hong Kong, four in the UAE, two in Malaysia, and one in Indonesia. This rule suspends license exceptions for exports, reexports, and transfers (in-country) involving these persons. In addition, exporters, reexporters, and transferors of goods subject to the Export Administration Regulations but not requiring a license to these persons must obtain (and keep a record of) a UVL statement from them before proceeding with the transaction.

The UVL contains the names and addresses of foreign persons who are or have been parties to a transaction involving the export, reexport, or transfer (in-country) of items subject to the EAR whose bona fides (i.e., legitimacy and reliability relating to the end-use and end-user of items subject to the EAR) BIS has been unable to verify through an end-use check; e.g., the check could not be completed satisfactorily for reasons outside the U.S. government’s control, or during a check a recipient of items subject to the EAR was unable to produce them for visual inspection or provide sufficient documentation or other evidence to confirm their disposition. BIS may place persons on the UVL when there is insufficient evidence to place them on the Entity List.

Shipments (1) removed from license exception eligibility or that are now subject to requirements in §744.15 of the EAR as a result of this rule, (2) eligible for export, reexport, or transfer (in-country) without a license before this rule, and (3) on dock for loading, on lighter, laden aboard an exporting carrier, or en route aboard a carrier to a port of export on April 11, pursuant to actual orders, may proceed to that UVL-listed person under the previous license exception eligibility or without a license so long as they have been exported from the U.S., reexported, or transferred (in-country) before May 13. Any such items not actually exported, reexported. or transferred (in-country) before midnight on May 13 will be subject to the requirements in §744.15 of the EAR in accordance with this rule.

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

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