Background

The Bureau of Industry and Security has issued a final rule that, effective Dec. 11, adds four entities in Russia, two in China, and two in Burma to the Entity List for actions facilitating human rights violations in these countries. For all of these entities BIS is imposing a license requirement for exports, reexports, and transfers (in-country) of all items subject to the Export Administration Regulations and a license application review policy of presumption of denial.

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. 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 Jan. 10. Any such items not actually exported, reexported, or transferred before midnight on Jan. 10 will require a license in accordance with this rule.

Copyright © 2025 Sandler, Travis & Rosenberg, P.A.; WorldTrade Interactive, Inc. All rights reserved.

ST&R: International Trade Law & Policy

Since 1977, we have set the standard for international trade lawyers and consultants, providing comprehensive and effective customs, import and export services to clients worldwide.

View Our Services 

Close

Cookie Consent

We have updated our Privacy Policy relating to our use of cookies on our website and the sharing of information. By continuing to use our website or subscribe to our publications, you agree to the Privacy Policy and Terms & Conditions.