Effective Dec. 16, the Bureau of Industry and Security has removed 36 entities in Russia, China, and Pakistan from the Unverified List. Nine entities have been moved to the Entity List because BIS was unable to verify their bona fides due to the foreign government’s prevention of timely end-use checks, while 27 entities were removed because BIS was able to verify their bona fides.
For those entities not being moved to the Entity List, this rule lifts the suspension of license exceptions for exports, reexports, and transfers (in-country) involving these entities and eliminates the requirement for exporters, reexporters, and transferors of goods subject to the Export Administration Regulations but not requiring a license to these entities to 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 entities that 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 entities on the UVL when there is insufficient evidence to place them on the Entity List.
For more information on restrictions on exports to entities on the Unverified List or other lists, please contact Kristine Pirnia.
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