24 Entities Affected by New Export Restrictions

Trade Update • Dec. 8, 2022

ffective December 8, 2022, a final rule by the Bureau of Industry and Security (BIS) has added 24 entities (companies) to the Entity List, as they have been determined by the U.S. Government to be acting contrary to the national security or foreign policy interests of the United States. These newly listed entities are under the destinations of Latvia, Pakistan, Russia, Singapore, Switzerland, and the United Arab Emirates (U.A.E.).

Moreover, the final rule has removed one entity from the Entity List under three entries: Oman, Saudi Arabia, and the U.A.E.

The Entity List identifies entities for which there is reasonable cause to believe, based on specific and articulable facts, that the entities have been involved, are involved, or pose a significant risk of being or becoming involved in activities contrary to the national security or foreign policy interests of the United States.

Exporter Requirement

Exporters are required to obtain a license for the newly added entities, and the Export Administration Regulations (EAR) now limit the availability of most license exceptions for exports, reexports, and transfers (in-country) when a listed entity is a party to the transaction.