Regulatory intelligence for US exporters

BIS Adds 28 to Entity List, Including 14 for Scheme to Send UAV Components to Russia

The Bureau of Industry and Security added 28 entities to the Entity List this week for various reasons, all falling under the umbrella of “acting contrary to the national security or foreign policy interests of the United States.” The final rule, effective Sept. 27, adds entities in China, Finland, Germany, Oman, Pakistan, Russia and the United Arab Emirates. It also modifies entries for two entities and removes a Military End User List entity.

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Nine of the entities were added because they were “implicated in a conspiracy to violate U.S. export controls, including a scheme to supply the Special Technology Center, an entity on the BIS Entity List, with components to make unmanned aerial vehicles (UAVs) for Russia’s Main Intelligence Directorate of the General Staff (GRU),” BIS said.

Those entities are Asia Pacific Links Ltd., under the destination of China; Evolog Oy, Luminor Oy and Siberica Oy of Finland; ICW-Industrial Components Weirich of Germany; and Device Consulting, Grant Instrument, SMT-iLogic, and Streloy of Russia.

“Our actions send a clear message to those trying to evade our export controls that there will be consequences for behavior that seeks to undermine U.S. national security interests,” Alan Estevez, BIS under secretary, said in a Sept. 25 news release. “We will not hesitate to take swift and meaningful action against those who continue seeking to supply and support Putin’s illegal and immoral war in Ukraine.”

Another two entities, Speed Business Trading (HK) Ltd. and Sunrising Logistics (HK) Ltd. of China, were added because they “have procured and/or attempted to procure U.S.-origin items that would ultimately support Iran’s weapons of mass destruction and UAV programs.”

BIS also is adding Nanjing Institute of Astronomical Optics and Technology, with a destination of China, to the Entity List for “procuring U.S.-origin items in likely furtherance of Chinese military research, and contrary to the national security and foreign policy interests of the United States.”

And BIS is adding International Smart Digital Interface Company (ISDIC) and associated individual Moaz Ahmed Mohammed al-Haifi to the Entity List under the destination of Oman, because of the support they have provided to Yemen-based Houthi forces, BIS said.

For these 14 entities, BIS is adding a license requirement for all items subject to the EAR, with a license review policy of denial.

Another seven entities are being added by BIS to the Entity for their “contributions to Pakistan’s unsafeguarded nuclear activities,” the agency said. That includes New Era Enterprises FZE under the destination of the UAE; Well Fair International (Hong Kong) Ltd., of China; and AHD International; Genesis Technical Consultancy Services; Indus Tooling Solution; Longford Engineering (Pvt) Ltd; and Polymaster Engineering, under the destination of Pakistan.

For these seven entities, BIS will require a license for all items subject to the EAR, with license review policies outlined in the EAR’s restrictions on nuclear-end uses.

BIS is adding one entity, VSMPO-AVISMA Corporation PJSC of Russia, “for representing a critical risk of diversion of U.S defense technologies.” BIS said the entity qualifies as a military-end user and will be subject to the Russia/Belarus-Military End User Foreign Direct Product rule. It’s being added with a license requirement for all items subject to the EAR, and a license review policy of denial.

Finally, another six entities are being added “for working as a network to procure aerospace components, including dual-use components for unmanned aerial vehicle applications, for the Iran Aircraft Manufacturing Company (HESA).” The components are being used to “develop and produce Shahed-series UAVs, which have been used by Iran to attack oil tankers in the Middle East and by Russia in Ukraine,” BIS said.

These six entities are Guilin Alpha Rubber & Plastics Technology Company Limited, Hangzhou Fuyang Koto Machinery Company Limited, Raven International Trade Limited, S&C Trade PTY Company Limited, Shenzhen Caspro Technology Company Limited (Shenzhen Caspro), all of China, as well as a Chinese employee of Shenzhen Caspro, Yun Xia Yuan.

All six also qualify as military end users, and will be subject to the Russia/Belarus-Military End User Foreign Direct Product rule, BIS said. They are being added with a license requirement for all items subject to the EAR, and a license policy of denial except for food and medicine designated as EAR99, “which will be reviewed on a case-by-case basis,” BIS said.

Beyond the 28 entities BIS is adding to the Entity List, it also is modifying an entry for Akhtar & Munir of Pakistan to add an alias and an address, as well as to revise the license review policy to reference that outlined in the EAR’s restrictions on nuclear-end uses. BIS also is modifying an entry for ICSOSO Electronics Co. Ltd. to add seven aliases and six addresses to the entry, the agency said.

BIS also is removing Zhejiang Perfect New Material Co., Ltd, an entity located in China, from the Military End User List. The agency said that the interagency End-User Review Committee decided to remove the entity “on the basis of a request for removal submitted to BIS.”