The Bureau of Industry and Security has issued a final rule that, effective Nov. 1, adds 14 entities in Türkiye, 13 in Russia, 11 in China, five in India, two in Malaysia, and one in Singapore to the Entity List. Reasons for adding these entities include diverting or transshipping U.S.-origin items to Russia, aiding Russia’s chemical and biological warfare programs or defense industrial base, supply Chinese entities on the Entity List, and engaging in evasive or misleading behavior regarding imports of U.S.-origin items during end-use checks.
For all of 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 (with some exceptions for food and medicine designated as EAR99).
This rule also designates 30 of the newly-added entities as Russian procurement entities, and modifies 52 existing entries under the destinations of China, Estonia, Finland, India, Turkey, the UAE, and the United Kingdom, so that they are subject to the Russia/Belarus military end-user and procurement foreign direct product rule.
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. 1 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. 2. Any such items not actually exported, reexported, or transferred before midnight on Dec. 2 will require a license in accordance with this rule.
Copyright © 2025 Sandler, Travis & Rosenberg, P.A.; WorldTrade Interactive, Inc. All rights reserved.