Background

The Bureau of Industry and Security has issued a final rule that, effective Jan. 31, adds seven entities in Iran to the Entity List. These entities are being added for contributing to Russia’s military and defense industrial base through the production of unmanned aerial vehicles that are being transferred to Russia for use in Ukraine.

For these seven entities BIS is imposing a license requirement for exports of all items subject to the Export Administration Regulations. BIS will review applications for such licenses under a policy of denial apart from food and medicine designated as EAR99, which will be reviewed on a case-by-case basis. No license exceptions will be available for exports, reexports, or transfers (in-country) to these entities.

BIS is also designating these entities as Russian or Belarusian military end-users under the 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 Jan. 31 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 March 3. Any such items not actually exported, reexported, or transferred before midnight on March 3 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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