BIS Adds Eleven to Entity List for Support to Chinese and Russian Militaries

On April 11, 2024, the Department of Commerce, Bureau of Industry and Security published a rule (89 FR 25503) adding eleven entries to the Entity List.  The April 11th additions are:

• China
  • Beijing Anwise Technology Co., Ltd.;
  • Jiangxi Xintuo Enterprise Co., Ltd.;
  • LINKZOL (Beijing) Technology Co., Ltd.;
  • Shenzhen Jiasibo Technology Co., Ltd.;
  • SITONHOLY (Tianjin) Co., Ltd.; and
  • Xi'an Like Innovative Information Technology Co., Ltd.
• Russia:
  • Aerosila JSC SPE;
  • Delta-Aero LLC; and
  • JSC ODK-Star.
• United Arab Emirates:
  • Khalaj Trading LLC; and
  • Mahdi Khalaj Amirhosseini.

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 restructions 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.

BIS also published a press release on these additions.  The listings were based on support for the People's Republic of China's (PRC) military modernization efforts, support of Military-Intelligence End Users through the acquisition of U.S.-origin items, actions related to unmanned aerial vehicles (UAVs) used by Iran and Russia, as well as support for Russia's defense industrial base.

The Entity List now includes over 600 Chinese entities, plus Chinese-linked entities worldwide. Support for Chinese military modernization and Russian military efforts are two of many foreign policy concerns addressed by the Entity List. Screening Chinese parties is a particular concern, but it should always be noted that parties in any country can end up on a sanctions list, as with the two new additions from the United Arab Emirates.