On March 2, 2023, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a Final Rule adding 37 entities to the Entity List for contributing to Russia’s military/defense industrial base, supporting China’s military modernization, and facilitating or engaging in human rights abuses in Burma and China, including the following:
- Three entities in Russia, Belarus and Taiwan have been added for significantly contributing to Russia’s military and/or defense industrial base;
- Eighteen Chinese entities have been added for acquiring and attempting to acquire U.S.- origin items in support of China’s military modernization efforts, and for supplying or attempting to supply a sanctioned entity in Iran;
- Six entities based in China and Burma have been added for violations of human rights; and
- Fourteen entities based in China and Pakistan have been added for contributing to ballistic missile programs of concern, including Pakistan’s missile program, and for involvement in unsafeguarded nuclear activities.
Specific details on each entity, including names and addresses, and BIS’ license review policy are available in the Final Rule. These additions to the Entity List are effective as of March 2, 2023. However, shipments to any of the new designees on the Entity List that were en route aboard a carrier on March 2, 2023, pursuant to actual orders for export, reexport, or transfer (in-country) to or within a foreign destination, may proceed to that destination under the previous eligibility for a License Exception or export, reexport, or transfer (in-country) without a license (NLR).