Commerce May Be Looking to CBP WROs for Entity List Additions, Lawyer Says
Exporters looking to comply with U.S. Entity List restrictions should pay close attention to foreign companies affected by a CBP withhold release order, which could later lead to U.S. export restrictions, said Sylvia Costelloe, a trade lawyer with Arent Fox.…
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Costelloe said at least two companies were subject to a WRO and later added to the Entity List, including China-based Hetian Haolin Hair Accessories (see 2005010040 and 2007200026). “What this indicates here in this space is that there might actually be some cooperation or some collaboration between CBP and Commerce,” Costelloe said during a June 16 Arent Fox webinar. While she said CBP doesn’t sit on the End-User Review Committee, which decides which entities to add and remove from the Entity List, Commerce still “might be looking to CBP when deciding whether or not to add certain entities to the Entity List.” Commerce didn’t immediately comment.