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Commerce Adds 13 to Entity List: Includes Canadian and European Entities Designated as Russian Military End Users

On February 27, 2023, the Department of Commerce, Bureau of Industry and Security (BIS) added ten companies in thirteen locations to the Entity List (88 FR 12170).

The Entity List, found at Supplement No. 4 to Part 744 of the Export Administration Regulations (EAR), restricts exports of U.S.-origin goods and technology to listed parties. For these additions, the restrictions create a license requirement with a presumption of denial for all exports, reexports, or transfers subject to the EAR. This includes items classified as EAR99 or other items that would otherwise be shipped No License Required, or NLR.

The companies, located in Canada, China, France, Luxembourg, Netherlands, and Russia, were added to the Entity List due to their contributions to Russia's military and/or defense industrial base.  Notably, they are also designated as Russian "military end users" subject to the Russia/Belarus-Military End User Foreign Direct Product (FDP) rule (EAR § 734.9(g)).

The new members of the Entity List are:

  • CPUNTO Inc. (Canada)
  • Electronic Network Inc. (Canada)
  • AOOK Technology Ltd. (China)
  • Beijing Ti-Tech Science and Technology Development Co. (China)
  • Beijing Yunze Technology Co., Ltd. (China)
  • China HEAD Aerospace Technology Co. (China)
  • Spacety Co. Ltd. (China)
  • China HEAD Aerospace Technology Co. (France)
  • Spacety Co., Ltd. (Luxembourg)
  • China HEAD Aerospace Technology Co. (Netherlands)
  • Dexias Industrial Products and Trade Limited Company (Russia)
  • Innovation and Technologies LLC (Russia)
  • Promtekhkomplekt JSC (Russia)

BIS also published a press release on this action and related sanctions.

With entities listed in countries outside of Russia (and especially close NATO and EU trading partners), this is a crucial reminder of the importance of screening parties in all countries.