Background

The Bureau of Industry and Security has issued a final rule that, effective Dec. 8, adds 24 entities in Latvia, Pakistan, Russia, Singapore, Switzerland, and the United Arab Emirates to the Entity List. BIS states that these entities are being added for a variety of reasons, including aiding Russia’s military and/or defense industrial base, supplying controlled items to Iran, and contributing to unsafeguarded nuclear activities and missile proliferation-related activities.

BIS is also removing from the Entity List one entity listed in three entries under Oman, Saudi Arabia, and the UAE.

This rule imposes a license requirement for exports to the newly added entities of all items subject to the Export Administration Regulations and provides that for most of these entities applications for such licenses will be reviewed under a presumption of denial. BIS notes that seven of these entities will also be subject to the Russia/Belarus military end-user foreign direct product rule, which imposes restrictions on their access to certain foreign-produced items.

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 Dec. 8 pursuant to actual orders for export, reexport, or transfer to or within a foreign destination may proceed to that destination under the previous eligibility.

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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