Regulatory intelligence for US exporters

BIS Updates Unverified List With 8 Additions, 2 Removals

The Bureau of Industry and Security this week added eight companies to its Unverified List after it was unable to verify the “legitimacy and reliability” of the entities through end-use checks, including their ability to responsibly receive controlled U.S. exports. It also removed two companies from the list after BIS said it was able to successfully conduct end-use checks.

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The additions, outlined in a final rule effective Oct. 16, include various technology, logistics and electronics companies, as well as other businesses in China, Germany, Pakistan and Turkey. If BIS can’t complete an end-use check on the companies added to the list within 60 days, it can move them to the more restrictive Entity List (see 2211170069, 2210070006 and 2212060059).

The companies aren’t subject to additional export license requirements but are no longer eligible for license exceptions, and all current exceptions will be suspended. Suppliers to those entities must also 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.

All exports that no longer qualify for a license exception as a result of this rule and that were aboard a carrier to a port as of Oct. 16 may proceed to their destinations under the previous eligibility as long as the items have been exported before Nov. 15, BIS said. Any items not exported before midnight Nov. 15 will be subject to UVL-related restrictions.

The new UVL companies are:

  • China-based Hengye Technology Co., Ltd.
  • China-based Skytop Electronics
  • China-based YXS Technology Co., Ltd.
  • Germany-based Arabian Aviation TradeGroup
  • Germany-based Tiptrans Limited
  • Pakistan-based Marshal Traders
  • Turkey-based Pegasus Technic Services
  • Turkey-based Vast Polymers, Ambalaj Sanayi Ve Ticaret Limited Sirketi.

The agency removed China-based Shengwei Technology Co., Ltd. and Saudi Arabia-based Al Gihaz Co., Ltd. for Contracting and Trading from the UVL because “BIS was able to verify their bona fides.”