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Exports Restricted to 33 Persons Added to Unverified List

Thursday, May 17, 2018
Sandler, Travis & Rosenberg Trade Report

The Bureau of Industry and Security has issued a final rule that, effective May 17, adds 33 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. The new entries consist of 12 persons located in Russia, 11 in China, five in the United Arab Emirates, two in Canada, and one each in Estonia, Finland, and Pakistan.

This rule suspends license exceptions for exports, reexports, and transfers (in-country) involving the newly listed persons, and 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 May 17, 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 June 18. Any such items not actually exported, reexported. or transferred (in-country) before midnight on June 18 will be subject to the requirements in §744.15 of the EAR in accordance with this rule.

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