BIS removes 40 persons and adds 26 to Unverified List — China, Hong Kong, Indonesia, UAE

Mechanism

The Unverified List (Supplement No. 6 to 15 CFR Part 744) is BIS's administrative tool for flagging foreign parties whose export-licence bona fides could not be confirmed through pre-licence checks or post-shipment end-use verifications (§744.15). UVL placement does not constitute a licence-denial presumption (that is the Entity List), but it does:

• Suspend EAR licence exceptions (LVS, GBS, CIV, etc.) for shipments to the listed party.
• Require US exporters to obtain a signed UVL Statement from the listed end-user before

shipping any item subject to the EAR.

• Subject the listed party to enhanced scrutiny in any future licence review.

This October 2020 rule is a combined addition/removal action — the largest class of routine UVL maintenance FR notices. The 40 removed parties were cleared either through a successful end-use verification (§744.15(c)(2)) or because the company was no longer registered to operate in the listed country. The 26 added parties were flagged because end-use checks could not be completed satisfactorily for reasons beyond US Government control (e.g., access denied, entity unresponsive, or local authorities unable to facilitate the check).

The countries associated with the 40 removals are China (CN), Hong Kong (HK), Indonesia (ID), and the United Arab Emirates (AE) — reflecting the typical distribution of BIS pre-shipment verification destinations for dual-use goods in this period.

Downstream implications

• US exporters shipping EAR-controlled items to any of the 26 newly added parties must

obtain a signed UVL Statement prior to export; failure to do so constitutes an EAR violation.

• The 40 removals represent cleared counterparties that no longer carry UVL restrictions —

exporters can resume relying on applicable licence exceptions.

• The mixed nature (large removals, moderate additions) is consistent with BIS's routine

administrative cycle for UVL maintenance and does not signal a targeted geopolitical escalation.

Open questions

• Specific entity names and country breakdown for the 26 additions are detailed in the

Federal Register document appendix; the Federal Register page did not render for direct scraping. Researchers should consult the FR document for the complete party list.