BIS Adds Eight and Removes Two From Unverified List
On October 16, 2024, the Department of Commerce, Bureau of Industry and Security (BIS) published a rule (89 FR 83428) adding eight entries to the Unverified List (UVL) and removing two. New UVL parties are located in China, Germany, Pakistan, and Turkey. The two removed parties are located in China and Saudi Arabia
With the inclusion of parties located in NATO allies such as Germany and Turkey, this action is a reminder of the importance of screening customers in all countries even when no license is believed to be required.
The Unverified List
The Unverified List (UVL) is administered by the U.S. Department of Commerce, Bureau of Industry and Security (BIS). The list itself is found in Supplement No. 6 to Part 744 of the Export Administration Regulations (EAR) and is updated through Federal Register Notices.
Parties may be added to the Unverified List if the US Government is unable to verify their bona fides (legitimacy and reliability) in an end-use check.
Parties listed on the Unverified List are ineligible to receive items subject to the EAR through license exceptions. The Unverified List does not create a freestanding BIS license requirement, but licenses are required due to unavailable license exceptions.
Transactions that do not require a license – EAR99 or No License Required (NLR) – require an Unverified List (UVL) statement from the listed party. The requirements for this statement are detailed in §744.15 and include name and contact information, an agreement to comply with the EAR, an end-use declaration, and agreement to cooperate with end-use checks. An Automated Export System (AES) filing is also required for exports to parties on the Unverified List.
The Unverified List currently includes 173 parties. Most of these are in China (including Hong Kong) and the UAE, but the list also includes parties around the world, from Canada to Bulgaria to Malaysia.
Parties may be removed from the Unverified List after a subsequent successful end-use check on the listed party. Listed parties may request removal in writing directly to BIS.