BIS Adds 37 to Entity List, Including for Illegal Exports to Russia, China
The Bureau of Industry and Security this week added 37 entities to the Entity List for a range of activities the agency said threaten U.S. national security, including for supporting Russia’s war effort, sending controlled items to China’s military and aiding companies already listed on the Entity List. The entities -- located in Belarus, Myanmar, China, Pakistan, Russia and Taiwan -- will be subject to a license requirement for all items subject to the Export Administration Regulations with varying license application review policies. BIS also modified 10 existing Chinese entries on the Entity List. The additions and changes took effect March 2.
Twenty-eight of the entities are located in China, including various logistics, electronics, communications, technology and cooling equipment companies. BIS said some of the Chinese firms sent controlled items to Iran -- specifically Paradazan System Namad Arman, an Iranian entity sanctioned by the Treasury Department -- while others supported China’s military modernization efforts. Other entities added to the list illegally provided items to Russia’s defense industrial base, contributed to surveillance efforts in China and Myanmar, supported ballistic missile programs “of concern” and collected and analyzed genetic data for China.
BIS listed varying license application review policies for the entities. Some will be subject to a review policy of presumption of denial or policy of denial, while others will be subject to case-by-case reviews for certain Export Control Classification Numbers or certain telecommunications infrastructure items. Other case-by-case reviews will be based off assessments about whether the exports may be used to proliferate certain rocket systems or unmanned drones.
Three entities -- Belarus-based DMT Trading, Russia-based DMT Electronics and Taiwan-based Neotec Semiconductor -- were designated as Russian or Belarusian military end-users and will be subject to the Russia/Belarus-Military End User Foreign Direct Product Rule. License applications for these entities will be reviewed under a policy of denial for all items subject to the EAR other than certain food and medicine designated as EAR99, which will be reviewed on a case-by-case basis.
All exports that now require a license as a result of the Entity List changes that were aboard a carrier to a port as of March 2 may proceed to their destinations under the previous eligibility, BIS said.
The agency also modified 10 existing Entity List entries in China to add aliases and addresses, and updated the license review policy to a presumption of denial for the Beijing University of Aeronautics and Astronautics.
The 37 new Entity List additions, added under 38 entries because one entity is listed under multiple destinations, are:
Belarus
Myanmar
China
Pakistan
Russia
Taiwan