US BIS adds six Russian technology entities to Entity List under EO 14024

Mechanism

BIS added six Russian entities under the authority of Executive Order 14024, signed by President Biden on 15 April 2021, which targets persons operating in sectors of the Russian economy and persons engaging in harmful foreign activities including malicious cyber operations, election interference, transnational corruption, and targeting dissidents. All six were already designated as Specially Designated Nationals (SDNs) by OFAC under EO 14024; this BIS action mirrors those designations onto the Entity List to impose export-control restrictions in addition to asset-freezing.

The six designated entities and their profiles:

1. Aktsionernoe Obshchestvo AST (Advanced Systems Technology) — IT services firm linked to Russian intelligence infrastructure. 2. Aktsionernoe Obshchestvo Pasit — technology company operating in Russia's IT sector with reported ties to Russian state security apparatus. 3. Aktsionernoe Obshchestvo Pozitiv Teknolodzhiz (JSC Positive Technologies) — prominent Russian cybersecurity company; CISA and NSA had previously warned that Positive Technologies conducts research supporting Russian intelligence and sells tools enabling intrusions against US and allied networks. 4. Federal State Autonomous Institution Military Innovative Technopolis Era (ERA) — Russia's flagship military-technology accelerator, operated by the Ministry of Defence near Anapa; develops AI, robotics, directed-energy, and hypersonic technologies for military application. 5. Federal State Autonomous Scientific Establishment Scientific Research Institute Specialized Security Computing Devices and Automation (NII Specvuzavtomatika) — defence research institute developing specialised secure computing hardware and automation for security/military end-users. 6. Obshchestvo S Ogranichennoi Otvetstvennostyu NEOBIT — Russian IT-security firm with reported contracts with the FSB, SVR, and Ministry of Defence.

The FSB entry on the existing Entity List was simultaneously revised to cite General Licence No. 1B (effective 2 March 2021) in place of the prior General Licence No. 1, updating the transaction authorisations available to US persons who must interact with FSB for product- certification purposes in Russia.

Downstream implications

• Establishes a template for the "EO 14024 mirror" approach: OFAC SDN designations under the

Russia harmful-activities EO are replicated on the BIS Entity List, applying a dual-layer restriction (asset freeze + export denial) to Russian technology actors.

• Positive Technologies designation was high-profile and signalled US intent to restrict Russian

offensive-cyber tooling supply chains well before the February 2022 invasion of Ukraine.

• ERA Technopolis designation restricts supply of dual-use components (semiconductors, sensors,

software) to Russia's military AI/hypersonics development hub.

• Sets precedent for subsequent large-scale Russia entity-list additions in 2022 (91-entity and

120-entity tranches following the Ukraine invasion).

Open questions

• Whether any non-US suppliers (EU, Japan, South Korea, Taiwan) applied equivalent controls on

these entities contemporaneously or only after the 2022 invasion.

• Scope of Positive Technologies' EU client exposure at the time of designation and whether EU

member states subsequently applied Article 8 NIS2 measures to its software products.