Two dozen overseas entities placed on restrictive US export control list

The U.S. Department of Commerce’s Bureau of Industry and Security (BIS) on March 16 added 24 companies and individuals to the Entity List for posing a risk to U.S. national security and foreign policy interests.

The Entity List subjects U.S. exporters to specific export licensing requirements and prohibitions when conducting business with the listed entities. Organizations or persons who violate U.S. export control rules – as defined under the Export Administration Regulations (EAR) – are subject to criminal penalties and administrative sanctions.

The newest additions to the Entity List include nine entities in Pakistan that are associated with the country’s missile technology program. Entities also were added to the list from Iran (six), United Arab Emirates (five), China (two), and Russia (two). A complete list of the entities’ names and locations is available in the Federal Register.

An End-User Review Committee (ERC), which is composed of export control officials from the Commerce, State, Defense, Energy and Treasury departments, decides which entities are added to the list.

The ERC, for example, determined that Iran Air, which was added to the Entity List on March 16, transports “military-related equipment” for Iran’s Islamic Revolutionary Guard Corps (IRGC) and Ministry of Defense and Armed Forces Logistics (MODAFL).

The Iranian air carrier also “has a history of diverting spare aircraft parts intended for civil aviation to military-linked entities and for military purposes,” BIS said.

Since last year, BIS has added numerous entities, mostly in China, to the Entity List, including the high-profile additions of Huawei Technologies Co. Ltd. and 114 of its overseas affiliates and subsidiaries in May 2019.