News
Print PDF

Practice Areas

Exports Restricted to Six Persons Added to Unverified List

Thursday, April 06, 2017
Sandler, Travis & Rosenberg Trade Report

The Bureau of Industry and Security has issued a final rule that, effective April 6, adds six 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. As a result, license exceptions are suspended for exports, reexports, and transfers (in-country) involving these 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.

This rule also revises two addresses and adds an alternate name for one person, and revises three addresses, adds three addresses, and adds an alternate name for another, who are already on the UVL.

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, either because an end-use check such as a pre-license check or post-shipment verification could not be completed satisfactorily for reasons outside the U.S. government’s control or because during an end-use check a recipient of items subject to the EAR was unable to produce those items for visual inspection or provide sufficient documentation or other evidence to confirm the disposition of those items. 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 6, 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 8. Any such items not actually exported, reexported. or transferred (in-country) before midnight on May 8 will be subject to the requirements in §744.15 of the EAR in accordance with this rule.

To get news like this in your inbox daily, subscribe to the Sandler, Travis & Rosenberg Trade Report.

Customs & International Headlines