Background

The Bureau of Industry and Security has issued a final rule that, effective April 11, adds six entities in China, three in Russia, and two in the United Arab Emirates to the Entity List.

These entities are being added for (1) transshipping controlled items through the UAE to Iran, (2) acquiring U.S.-origin items in support of China’s military modernization efforts, (3) supporting Russia’s military, or (4) procuring aerospace components for Iran.

For the listed entities BIS is imposing a license requirement for exports of all items subject to the Export Administration Regulations and a license application review policy of denial (other than for food and medicine designated as EAR99) or presumption of denial. BIS is also designating five of these entities as Russian or Belarusian military end-users, which subjects them to the associated foreign direct product rule.

Shipments of items removed from eligibility for a license exception or for export, reexport, or transfer (in-country) without a license (NLR) as a result of this rule that were en route aboard a carrier to a port of export, reexport, or transfer on April 11 pursuant to actual orders for export, reexport, or transfer to or within a foreign destination may proceed to that destination under the previous eligibility before May 13. Any such items not actually exported, reexported, or transferred before midnight on May 13 will require a license in accordance with this rule.

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

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