The Bureau of Industry and Security has issued a final rule that, effective Nov. 17, adds two entities each in Panama and Venezuela, and one entity each in Costa Rica, Ecuador, India, Spain, and Russia, to the Entity List.
Most of these entities are being added for circumventing U.S. sanctions against Venezuela by concealing the true end-user and end-destination of exports using misrepresentations and fraudulent documents, including the filing of false electronic export information. For these entities BIS is imposing a license requirement for exports of all items subject to the Export Administration Regulations and a license application review policy of presumption of denial.
One entity is being added for providing support to Russia’s military and/or defense industrial base. For this entity BIS is imposing a license requirement for exports of all items subject to the EAR with a license application review policy of denial.
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 Nov. 17 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 Dec. 18. Any such items not actually exported, reexported, or transferred before midnight on Dec. 18 will require a license in accordance with this rule.
Separately, BIS has issued a final rule removing one entity from China from the Entity List, effective Nov. 16.
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.
Copyright © 2025 Sandler, Travis & Rosenberg, P.A.; WorldTrade Interactive, Inc. All rights reserved.