Background

The Bureau of Industry and Security has issued a final rule that, effective Jan. 14, added one entity in China to the Entity List, added one entity in China to the Military End-User List, and removed two entities from Russia from the MEU List.

Entity List

China National Offshore Oil Corporation Ltd. has been added to the Entity List due to its involvement in China’s efforts to assert unlawful maritime claims in the South China Sea and intimidate and coerce other regional coastal states from accessing and developing offshore marine resources.

For this entity BIS has imposed a license requirement that applies to all items subject to the Export Administration Regulations except for (1) crude oil, condensates, aromatics, natural gas liquids, hydrocarbon gas liquids, natural gas plant liquids, refined petroleum products, liquefied natural gas, natural gas, synthetic natural gas, and compressed natural gas identified under one of 37 specified HTSUS subheadings and (2) items required for the continued operation of joint ventures with persons from countries in Country Group A:1 not operating in the South China Sea. The license review policy will be presumption of denial and no license exceptions will be available for exports, reexports, or transfers (in-country) to this entity.

MEU List

Beijing Skyrizon Aviation Industry Investment Co. Ltd. has been added to the MEU list. Exports, reexports, or transfers (in-country) of designated items to this entity will require a license, but BIS’ license review policy will be presumption of denial. In addition, no license exceptions are available for such shipments except those authorized under the provisions of license exception GOV.

BIS is also removing two entities in Russia from the MEU list, one because it is a duplicate listing of an entity specifically excluded from the MEU because it is not a military end-user and the other because it is already on the Entity List.

Shipments of items removed from license exception eligibility or for export or reexport without a license (NLR) as a result of this rule that were en route aboard a carrier to a port of export or reexport on Jan. 14 pursuant to actual orders for export or reexport to a foreign destination may proceed to that destination under the previous license exception eligibility or without a license.

For more information on restrictions on exports to persons on the Entity List or other lists, please contact Kristine Pirnia.

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