Background

The Bureau of Industry and Security has issued a final rule that, effective Sept. 30, adds 56 entities in Russia and one in Crimea to the Entity List. BIS states that these entities are being added for a variety of reasons, including acquiring or attempting to acquire U.S.-origin items in support of Russia’s military or being involved in the development of quantum computing technologies.

This rule imposes a license requirement for exports to these entities of all items subject to the Export Administration Regulations and provides that applications for such licenses will be reviewed under a presumption of denial (with exceptions for some with respect to food and medicine designated as EAR99 and items for U.S. government-supported use in the International Space Station).

BIS notes that 50 of the 57 entities will also be subject to the Russia/Belarus military end-user foreign direct product rule, which imposes restrictions on these entities’ access to certain foreign-produced items.

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 Sept. 30 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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