The Bureau of Industry and Security has issued a final rule that, effective Oct. 23, adds 16 entities in Pakistan, six in China, three in the United Arab Emirates, and one in Pakistan to the Entity List. Reasons for adding these entities include (1) dilatory and evasive conduct during end-use checks, (2) evading U.S. sanctions and export controls on Russia, (3) acting as front companies and procurement agents for a company already on the Entity List, (4) contributions to Pakistan’s ballistic missile program, (5) acquiring U.S.-origin items in support of China’s military modernization, and (6) procurement of U.S.-origin items for Iran’s weapons of mass destruction and unmanned aerial vehicle programs.
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.
This rule also removes two entities from the Entity List, one (from China) following its dissolution and the other (listed under the destinations of Canada, India, Japan, Malaysia, Sweden, and the UAE) following significant reforms to its corporate governance and business practices to address and prevent the misuse of its technology in ways that undermine democracy and abuse human rights.
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 Oct. 23 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 Nov. 22. Any such items not actually exported, reexported, or transferred before midnight on Nov. 22 will require a license in accordance with this rule.
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