BIS Adds 36 to Entity List
On June 30, 2022, the Department of Commerce's Bureau of Industry and Security (BIS) published a rule (87 FR 38920) adding thirty-six entries to the Entity List effective June 28, 2022.
The Entity List, which is found in Supplement No. 4 to Part 744 of the Export Administration Regulations (EAR), includes both individuals and entities involved in “activities that are contrary to the national security or foreign policy interests of the United States.” Listed entities are subject to license requirements for EAR-controlled items (including EAR99 or other items that would otherwise be shipped No License Required, or NLR), typically with a presumption of denial. License exceptions are not available for exports, reexports, or transfers to the entities.
The new members of the Entity List are located in:
- China
- Lithuania
- Pakistan
- Russia
- Singapore
- United Arab Emirates
- United Kingdom
- Uzbekistan
- Vietnam
Reasons for listing include providing support to Russia's military and/or defense industrial base, supplying or attempting to supply Iran with U.S.-origin electronics, and other attempts to acquire U.S.-origin items in support of military activities in China.
The rule also revises eleven existing entries and removes two following review of requests for removal. In one case, an address was removed because the Entity List had identified a company, Oriental Logistics Group Ltd., with a nearly identical name to the one actually targeted.
With many entities listed in non-sanctioned countries, including companies with ties to China located NATO and EU countries, this is a reminder of the importance of screening parties in all countries.