Russian Entities in Germany & Switzerland Included in Entity List Update
On Thursday, March 4, 2021, the U.S. Department of Commerce, Bureau of Industry and Security (BIS) added fourteen entities to the Entity List and corrected six others. The new listings were part of coordinated sanctions by the Departments of State, Commerce, and Treasury.
This action targets Russia for chemical weapons activities, but notably includes Russian-linked entities in Germany and Switzerland:
- Chimconnect GmbH (Germany)
- Pharmcontract GmbH (Germany)
- Riol-Chemie (Germany)
- Chimconnect AG (Switzerland)
The Entity List imposes a license requirement for all items subject to the EAR with a WMD proliferation-related license review policy outlined in the Export Administration Regulations (EAR) Part 744.
This serves as an important reminder that not only is the Entity List subject to change, but screening only when a country of concern (e.g., Russia) comes up is not enough to maintain export compliance. Sanctions directed at one country frequently affect entities located in other countries.