Regulatory intelligence for US exporters

BIS Adds 4 Companies to Entity List for Illegal Exports to Russia, Venezuela

The Bureau of Industry and Security added four entities to the Entity List last week after the agency said they illegally supplied U.S. items and parts to Russia or Venezuela. The companies, which have locations in Costa Rica, Ecuador, India, Panama, Spain, Russia and Venezuela, either supplied U.S.-origin integrated circuits to Russia’s defense sector or helped the Nicolas Maduro-led regime in Venezuela illegally acquire export-controlled aircraft parts.

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Effective Nov. 17, the companies are subject to license requirements for all items subject to the Export Administration Regulations.

Aerofalcon S.L., Novax Group S.A. and Zero Waste Global SA, helped Maduro representatives evade U.S. sanctions to acquire the aircraft parts. BIS said the three companies helped conceal the exports' actual end user and end destination, including by filing false Electronic Export Information for the shipments in the Automated Export System. Those companies will be subject to a license review policy of presumption of denial.

BIS also added India-based Si2 Microsystems Private Limited, which since March 1 has supplied U.S. circuits to Russian consignees with ties to the Russian defense sector. Those items included integrated circuits classified under Harmonized System-6 codes 854231, 854232, 854233, and/or 854239, which are some of the codes listed under BIS’ list of the most common high-priority items that Russia is seeking to acquire in violation of U.S. export controls. The company will be subject to a license preview policy of denial.

All exports that now require a license as a result of this rule but were aboard a carrier to a port as of Nov. 17 may proceed to their destinations under the previous eligibility as long as the items are exported before Dec. 18, BIS said. Any items not exported before midnight Dec. 18 will require a license.