On October 21, 2024, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a Final Rule adding 26 companies to its Entity List for activities contrary to U.S. national security and foreign policy for alleged violations of export controls, involvement in weapons programs of concern, and evasion of U.S. sanctions and export controls on Russia and Iran. The 26 new entries are from: the People’s Republic of China (6), Egypt (1), Pakistan (16), and the United Arab Emirates (UAE) (3). The reasons for the listing are as follows:
- Nine of the Pakistani entities were added for acting as front companies and procurement agents for a previously identified company added to the Entity List in 2014. The remaining seven Pakistani entities were added for contributions to Pakistan’s ballistic missile program.
- The three entities under the destination of the UAE and one under the destination of Egypt were added for acquiring and attempting to acquire U.S.-origin parts to evade U.S. sanctions and export controls imposed on Russia.
- The six entities under the destination of China were added for acquiring U.S.-origin items in support of that country’s military modernization, dilatory and evasive conduct during end-use checks, and procurement of U.S.-origin items for Iran’s weapons of mass destruction and unmanned aerial vehicle (UAV) programs.
Additional identifying information on each of these entities is available here. The Entity List identifies entities for which there is reasonable cause to believe that the entities present a high diversion risk, have been involved, are involved, or pose a significant risk of being or becoming involved in activities contrary to the national security or foreign policy interests of the United States. The Entity List specifies the license requirements that BIS imposes on each listed entity. Such license requirements are independent of, and in addition to, license requirements imposed elsewhere in the EAR. For these 26 entities, a license is required from BIS for all items subject to the Export Administration Regulations (EAR). License applications will be reviewed under a presumption of denial.
For the changes being made in this Final Rule, shipments of items removed from eligibility for a License Exception or export, reexport, or transfer (in-country) without a license (NLR) as a result of this regulatory action that were en route aboard a carrier to a port of export, reexport, or transfer (in-country), on October 23, 2024, 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) before November 22, 2024. Any such items not actually exported, reexported or transferred (in-country) before midnight, on November 22, 2024, require a license in accordance with this Final Rule.