The Bureau of Industry and Security has issued separate final rules (available here and here) adding add a total of 82 entities to the Entity List for various reasons, including aiding nuclear or defense capabilities in China, Pakistan, and Iran. Most of the entities being added (53) are located in China, with others in Pakistan (19), the United Arab Emirates (4), South Africa (3), Iran (2), and Taiwan (1).
BIS states that the goals of these additions include (1) restricting China’s ability to acquire and develop high-performance and exascale computing capabilities, as well as quantum technologies, for military applications, (2) impeding China’s development of its hypersonic weapons program, (3) preventing entities from using U.S. items to train Chinese military forces, (4) disrupting Iran’s procurement of unmanned aerial vehicles and related defense items, and (5) impairing the development of unsafeguarded nuclear activities and ballistic missile programs.
For all 82 entities BIS is imposing a license requirement for exports, reexports, and transfers (in-country) of all items subject to the Export Administration Regulations. Applications for such licenses will be reviewed under a presumption of denial for most of these entities. In addition, some are being added to the Entity List with a designation meaning that “items subject to the EAR” includes foreign-produced items.
BIS is also modifying one existing entity under four entries under the destinations of France, Iran, Senegal, and the United Kingdom.
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 these rules that were en route aboard a carrier to a port of export, reexport, or transfer on the effective date of the applicable rule (March 25 or March 28) 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 April 24 or April 28, respectively. Any such items not actually exported, reexported, or transferred before midnight on April 24 or April 28 will require a license in accordance with these rules.
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