BIS Entity List: 91 Russia-War Enablers Across 10 Destinations

Mechanism

Published 9 March 2022 with retroactive effect from 3 March 2022, this rule is the first BIS entity-list sweep directly tied to Russia's renewed invasion of Ukraine. Unlike the broader EAR rule changes (which revised license requirements and Russia/Belarus country groups), this action targets specific legal persons determined under EAR §744.11(b) to be acting contrary to US national security or foreign policy interests.

96 entries covering 91 distinct entities are spread across ten jurisdictions:

• Russia (majority): United Shipbuilding Corporation subsidiaries (shipyards and

design bureaus), defense electronics firms (JSC Element, NII Submikron, Elara, Radioavtomatika), aerospace companies (Russian Space Systems), nuclear engineering institutes, and chemical/analytical research organizations.

• Third-country front/transit nodes: Entities in Belize, Estonia, Kazakhstan, Latvia,

Malta, Singapore, Slovakia, Spain, and the United Kingdom suspected of serving as procurement conduits that route EAR-controlled items to Russia, bypassing direct-export controls.

License requirements: All items subject to the EAR require a license for export, reexport, or in-country transfer to any listed entity.

Review policy:

• Denial — applied to 86 of the 91 entities; essentially a near-total embargo.
• Case-by-case — applied to five space-sector entities (Elara, JSC Element,

Radioavtomatika, Russian Space Systems, NII Submikron) specifically for transactions supporting US Government-backed space programs; all other transactions presumed denied.

The rule was issued as an immediately effective final rule (no notice-and-comment period) under the foreign affairs exemption to the Administrative Procedure Act, consistent with the broader emergency EAR rule-making posture adopted after 24 February 2022.

Downstream implications

• Expands the Russia entity-list perimeter beyond purely military end-users to include

civilian and dual-use industrial companies in the shipbuilding, electronics, and nuclear sectors, significantly widening EAR enforcement surface.

• Third-country entries (KZ, EE, SG, etc.) signal BIS's intention to pursue transshipment

nodes, presaging later entity-list rounds targeting Kazakhstan and UAE diversion networks.

• The five space carve-outs reflect NASA/SpaceX cooperation dependencies (ISS operations)

still active at the time; these were subsequently wound down through 2022-2023.

• Shapes compliance due-diligence requirements for exporters dealing with distributors and

resellers in the listed third countries.

Open questions

• Which of the third-country front companies (Malta, Singapore, Belize, Slovakia, Spain)

were subsequently removed or escalated to denied-party status as ISS cooperation ended?

• Did BIS issue corrections/amendments to any of the 96 entries? (See the

2022-06-01 correction filing for Kaliningradnefteprodukt, which corrected a separate entity-list round.)