Denied Party Digest

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BIS Adds 33 Chinese Entities to Unverified List

On February 8, 2022, the Department of Commerce's Bureau of Industry and Security (BIS) published a rule (87 FR 7037) adding thirty-three entities in China to the Unverified List (UVL). The Unverified List, which is found in the Export Administration Regulations (EAR), Supplement No. 6 to Part 744, identifies parties for which the US Government was unable to verify the 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.  Transactions that do not require a license – i.e., EAR99 or No License Required (NLR) – require an Unverified List (UVL) statement from the listed party. The requirements for this statement are detailed in EAR §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.

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.

The Unverified List now includes 187 parties. More than half of these are in China, but the list also includes parties around the world, from Canada to Malaysia.

BIS also published a press release on this action.