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Export Restrictions on EAR-Regulated Goods Added, Revised

Monday, March 16, 2020
Sandler, Travis & Rosenberg Trade Report

The Bureau of Industry and Security has issued a final rule that, effective March 16, adds 24 foreign entities to the Entity List, which lists entities restricted from receiving U.S. exports of goods controlled under the Export Administration Regulations. This rule also revises five existing entries on the Entity List under the destinations of France, Iran, Lebanon, Singapore, and the United Kingdom.

The new additions consist of two entities in China, six in Iran, nine in Pakistan, two in Russia, and five in the United Arab Emirates. Reasons for these additions include procurement of goods on behalf of restricted companies, involvement in nuclear-related activities, contributions to Pakistan’s missile program, transshipment of U.S.-origin commodities to Iran, providing false and misleading information during end-use checks, and falsifying official documents to obfuscate the true end-users of items subject to the EAR.

BIS is imposing a license requirement for exports of all items subject to the EAR to the 24 named entities, along with a license review policy of presumption of denial for 20 of them. 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 March 16 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.

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