Regulatory intelligence for US exporters

BIS Adds 32 to Unverified List

The Bureau of Industry and Security this week added 32 parties to its Unverified List after it was unable to verify their “legitimacy and reliability” for receiving export-controlled items. The additions include 14 entries in China, five in the United Arab Emirates, four in Turkey, two in Germany and one each in Bulgaria, Canada, Indonesia, Israel, Malaysia, Saudi Arabia and Singapore.

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The additions, effective March 24, include Chinese electronics and technology companies, a Canadian drone product supplier, contracting and trading businesses and an industrial supply company. The companies and parties aren’t subject to additional export license requirements, but they are no longer eligible for license exceptions. Suppliers to those entities must obtain a statement from the UVL party that certifies, among other things, that the party won’t use the shipment for any activity prohibited by the Export Administration Regulations. Exporters must also file Electronic Export Information in the Automated Export System for all exports of “tangible items” subject to the EAR if the transactions involve parties on the UVL.

BIS last year announced a policy change that allows it to move a company from the UVL to the more restrictive Entity List if the agency can’t complete an end-use check within 60 days (see 2211170069). “It is critical that BIS is able to conduct end-use checks to determine compliance with U.S. export control rules,” Matt Axelrod, BIS’ top export enforcement official, said in an emailed press release. “Where we cannot verify the bona fides of foreign parties, we will continue to add parties to the Unverified List to place restrictions on future export transactions and prevent the diversion of U.S. items.”

All exports that no longer qualify for a license exception as a result of this rule that were aboard a carrier to a port as of March 24 may proceed to their destinations under the previous eligibility as long as the items have been exported before April 22, BIS said. Any items not exported before midnight April 22 will be subject to UVL-related restrictions.