BIS adds 60 entities (61 entries) to Entity List — China, Hong Kong, Indonesia, Malaysia, Oman, Pakistan, Russia, France, Switzerland, UAE

Mechanism

BIS exercised its authority under the Export Control Reform Act of 2018 (ECRA, 50 U.S.C. §§ 4801–4852) and the Export Administration Regulations (15 CFR Parts 730–774) to add sixty entities across ten destinations to the Entity List. All listed entities are subject to a licence requirement for all items subject to the EAR, with a licence review policy of presumption of denial.

The designations covered entities in:

• China / Hong Kong — the largest share, consistent with the ongoing US-China technology

and export-control friction that accelerated sharply in 2020. Entities likely include technology companies, research institutes, and state-linked procurement vehicles.

• Pakistan — characteristically linked to nuclear and missile proliferation procurement networks.
• Malaysia, Indonesia, Oman, UAE — transshipment and re-export intermediary concerns;

these Gulf and Southeast Asian hubs repeatedly appear in Entity List actions as conduits for sanctioned-country end-users.

• Russia — pre-2022 addition targeting specific defence/dual-use procurement actors.
• France and Switzerland — unusual Western-country designations, likely involving individuals

or shell entities engaged in illicit procurement on behalf of sanctioned-country programmes.

The rule simultaneously revised five existing entries under Canada, Germany, Hong Kong, Iran, and the UAE — typically to update aliases, addresses, or subsidiary listings.

Downstream implications

• Exporters must obtain a BIS licence before shipping any EAR-subject item to the sixty listed

entities; the presumption-of-denial policy makes approvals effectively unavailable for most commercial transactions.

• The Malaysia/Indonesia/Oman/UAE cluster reinforces BIS's sustained focus on third-country

transshipment intermediaries supplying China and other adversary-country end-users.

• The Pakistan designations continue the longstanding US effort to close nuclear and missile

component procurement channels.

• French and Swiss designations signal that BIS applies entity-list controls to Western

intermediaries when evidence of illicit re-export activity is established.

Open questions

• Full entity names and specific sectors are not extracted here; consult the Federal Register

PDF for the complete annex table by destination country.

• Whether any of the China entities were later incorporated into the SMIC/Huawei cluster actions

(December 2020) is not confirmed.