US BIS Entity List: 120 Russia and Belarus Military-Industrial Entities

Mechanism

BIS used its standard Entity List authority under EAR Part 744 to list 120 Russian and Belarusian entities. The rule applies a policy of denial (PD) for license applications covering all items subject to the EAR — hardware, software, and technology across all Export Control Classification Numbers (ECCNs), including EAR99 items — and prohibits use of all license exceptions. This is the most restrictive possible Entity List designation short of outright embargo, since even EAR99 consumer goods require a license that will be denied.

Ninety-five of the 120 entities are concurrently designated under Footnote 3 (the military end user marker introduced in February 2022). This triggers the Russian and Belarusian Military End User Foreign-Direct Product Rule (MEU FDP Rule): foreign-produced items that are the direct product of US-origin technology or software controlled under specified ECCNs become subject to the EAR if destined for these entities, even if the exporting country is a US ally. In practice, this extends the US denial to supply chains in third countries (EU, UK, Japan, South Korea, Taiwan) when their products are traceable to US technology.

The remaining 25 entities receive standard denial-policy listing without the Footnote 3 MEU designation, limiting extraterritorial reach to US-origin goods only.

Downstream implications

• Combined with the February–March 2022 Russia EAR sanctions rules (FR 2022-04300 et seq.),

this action erects a comprehensive denial perimeter around 120 specific Russian and Belarusian military-industrial nodes — aiming to degrade Russia's capacity to resupply precision munitions, radar, avionics, and electronic warfare systems drawing on Western components.

• The MEU FDP Rule designation on 95 entities forces non-US suppliers in allied jurisdictions to

screen orders against these names or face US enforcement risk — extending compliance burden beyond the US export community.

• In total, BIS added 260 entities to the Entity List in response to Russia's Ukraine invasion

across multiple rule packages through April 2022.

Open questions

• Full list of named entities is in the FR document appendix; tracking which entities were later

added to OFAC SDN or Sectoral lists would clarify layering of financial vs. export controls.

• Enforcement actions against third-country suppliers violating the MEU FDP Rule via this cohort

have not yet surfaced publicly as of filing date.