Background

The Bureau of Industry and Security has issued a final rule that, effective July 12, added 34 entities under 43 entries to the Entity List for actions such as facilitating exports of U.S. items to Iran, involvement in human rights violations and abuses in China’s Xinjiang Uyghur Autonomous Region, attempting to support China’s military modernization, and exporting goods to restricted entities. The entries include 23 in China; six in Russia; two each in Canada, Iran, and Lebanon; and one each in the Netherlands, Pakistan, Singapore, South Korea, Taiwan, Turkey, the United Arab Emirates, and the United Kingdom.

This rule also removes one entity in Germany from the Entity List, removes from the Unverified List an entity being added to the Entity List, and adds one entity in Russia to the military end-user list.

For 18 of the 34 entities being added to the Entity List, BIS is imposing a license requirement for all items subject to the Export Administration Regulations and a license review policy of presumption of denial. For another 13 entities BIS is imposing a license review policy of case-by-case review for (1) ECCNs 1A004.c, 1A004.d, 1A995, 1A999.a., 1D003, 2A983, 2D983, and 2E983, (2) EAR99 items described in the note to ECCN 1A995, and (3) items necessary to detect, identify, and treat infectious disease. There will be a presumption of denial for all other items subject to the EAR for these 13 entities. Moreover, no license exceptions are available for exports, reexports or transfers (in-country) to these entities.

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 July 12 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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