Background

The Bureau of Industry and Security has issued a final rule that, effective March 2, added 27 entities in China, four in Pakistan, three in Burma, and one each in Russia, Taiwan, and Belarus to the Entity List. This rule also modified ten Entity List entries for China.

BIS added these entities for various reasons, including (1) supplying controlled items to a restricted entity in Iran, (2) supporting China’s military modernization, (3) contributing to ballistic missile programs of concern, (4) being involved in unsafeguarded nuclear activities and missile-related activities, (5) collecting and analyzing genetic data that present a significant risk of diversion to China’s military programs, (6) providing surveillance equipment and services to Burma’s military regime, and (7) contributing to Russia’s military and/or defense industrial base.

For all of these entities BIS is imposing a license requirement for exports of all items subject to the Export Administration Regulations. BIS will review license applications for some of these entities under a presumption of denial, others will be reviewed pursuant to 15 CFR 744.2(d) and 744.3(d), and still others will be reviewed on a case-by-case basis.

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 March 2 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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