BIS to Add 26 to Entity List for Breaching Export Controls or Avoiding End-Use Checks

The new entries, located in China, Egypt, Pakistan and the United Arab Emirates, either tried to buy controlled U.S. items for China’s military, evade sanctions against Russia, supply sensitive goods to Iran and Pakistan or act as procurement agents for a Pakistan organization that was already on the Entity List, BIS said in a final rule released Oct. 21 and effective Oct. 23. Others didn’t cooperate with BIS after they were first placed on the less restrictive Unverified List.

BIS will also remove two entities from the list and update the address information for another entity.

The newly added parties will be subject to license requirements for all items subject to the Export Administration Regulations, and licenses will be reviewed under a presumption of denial.

“Our actions today send a message to malicious actors that if they violate our controls, they will pay a price,” BIS Undersecretary Alan Estevez said.

Most of the additions are located in Pakistan, including Ansar Mahmood, Combine Communications, Engineering Aura, Haris Fazal, Mansoor Ahmed Malik, Rehman Feroze, Technologic Enterprises, United Institute of Technical Professional Education and Usman Feroze. BIS said they either acted as front companies or as procurement agents for Advanced Engineering Research Organization, a Pakistan-based company that has been on the Entity List since 2014 and that has used other companies to buy U.S. items, “disguising” their end uses and end users from U.S. exporters.

The organization has bought controlled U.S. items for Pakistan’s Air Weapons Complex, a Pakistani government agency that was added to the Entity List in 2016 because it oversees the country’s cruise missile and drone programs, BIS said.

The agency also will add Pakistan-based Asia Pacific Trade Hub, Innovative Equipment (Private) Limited, Konsult Tek (Pvt) Ltd, Marriala Consultants, Metal Paint Products (Pvt) Ltd, Rockside Enterprise and Zaheer & Sons to the Entity List making “contributions” to Pakistan’s ballistic missile program.

Other entities will be added for supplying weapons programs run by Iran, including China-based Detail Technology (HK) Limited, L-Tong Electronic Technology Company and Shenzhen Jiachuang Weiye Technology Company, Ltd. BIS said they procured or “attempted to procure” U.S.-origin items for Iran's weapons of mass destruction and unmanned aerial vehicle programs.

Thea Kendler, the BIS assistant secretary for export administration, said “programs such as Iran’s WMD program, their unmanned aerial vehicle program, and Pakistan’s ballistic missile program pose significant threats to the national security of the United States and will not be aided by U.S. technologies.”

The rule will also add China-based Beijing Moreget Creative Technology Co., Ltd. to the list for buying or trying to buy U.S.-origin aviation simulation technology-related items for China’s military modernization efforts. Other companies in China, including closely connected businesses Shenzhen Dragonfly Supply Chain Co., Ltd. and Small Leopard Electronics Co., Limited, will be added after BIS said Small Leopard Electronics was part of a transaction with an end user “now understood to be a supplier of goods” to an Iranian procurement network.

BIS also said Small Leopard “repeatedly engaged in dilatory and evasive conduct” during a BIS end-use check after the company was added to the Unverified List in 2023 (see 2303230021). A policy change announced by BIS in 2022 allows the agency 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).

These listings “make clear that when foreign parties engage in dilatory or evasive conduct with respect to our end-use checks, they will face consequences,” said Matthew Axelrod, the BIS assistant secretary for export enforcement.

The agency also will add Egypt-based Steel Design LLC, along with Ahmed Abdellatif, Ayman Elgindy and Steel Design FZE, located in the UAE, for trying to buy civil aircraft parts for a Russian buyer. BIS said they tried to “evade the sanctions and export controls imposed” against Russia since the country invaded Ukraine in 2022.

All exports that now require a license as a result of this rule but were aboard a carrier to a port as of Oct. 23 may proceed to their destinations under the previous eligibility as long as the items are exported before Nov. 22, BIS said. Any items not exported before midnight Nov. 22 will require a license.

The rule also will remove two entities from the Entity List after BIS said the End-User Review Committee, the interagency group that makes decisions on Entity List updates, received “new information” that warranted their removal. BIS will remove Canada-headquartered technology software company Sandvine Inc. from the list after the agency said it took “significant” steps to improve its human rights controls, including by overhauling its corporate structure and business model and by leaving markets that had been using its products to breach human rights (see 2410210021).

BIS also will remove China-based Heifi from the list “following its dissolution.”

The rule also will update the Entity List entry for China-based Chengdu Poyotencon Technology by adding a new address.