Background

The Bureau of Industry and Security has issued a final rule that, effective March 4, added 14 new entities to its Entity List, which lists entities restricted from receiving U.S. exports of goods controlled under the Export Administration Regulations. These include ten entities in Russia, three in Germany, and one in Switzerland. They are being added based on their proliferation activities in support of Russia’s weapons of mass destruction programs and chemical weapons activities.

For these 14 entities BIS is imposing a license requirement for any transaction in which (1) items subject to the EAR are to be exported, reexported, or transferred (in-country) and (2) any of these entities act as purchaser, intermediate consignee, ultimate consignee, or end-user. For one entity BIS will use the review policy that applies to items destined for certain chemical and biological weapons end-uses, while for the other 13 BIS will use the review policy that applies to items destined for certain nuclear and missile technology end-uses. In addition, no license exceptions are available for exports, reexports, or transfers (in-country) involving these entities. 

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 March 4 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 attorney Kristine Pirnia via email.

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