BIS Entity List: 71 Russia and Belarus Military-Linked Entities Added

Mechanism

BIS exercised its authority under the Export Administration Regulations (EAR) to designate 71 entities as posing an unacceptable risk of diversion to Russia's military program. The designation triggers an export license requirement for virtually all EAR-subject items destined for these entities, with a presumption of denial — meaning no licenses will be approved except for limited humanitarian items (food, medicine) reviewed case-by-case.

The 70 Russian entities span the core of Russia's military-industrial complex:

• Aerospace and aviation manufacturing: Sukhoi design bureaus, Ilyushin Aviation Complex,

Novosibirsk and Irkutsk aircraft plants, MiG-linked facilities

• Naval and shipbuilding: Marine design bureaus including St. Petersburg Naval Design

Bureau Almaz and submarine design organizations (Rubin, Lazurit, Malachite bureaus)

• Electronics and communications: Concern Radio-Electronic Technologies (KRET) branches,

radar and navigation system manufacturers

• Nuclear and research: Russian Federal Nuclear Center (All Russian Research Institute of

Experimental Physics / VNIIEF), Russian Academy of Sciences institutes

• Energy: Gazprom Neft Shelf (offshore oil and gas operations)
• Chemical and propulsion: Chemical propulsion system manufacturers and machine-building

facilities

The sole Belarusian entity, JSC Eleron, was designated for supporting Russian military end use.

Sixty-six of the 71 entities receive a "footnote 3" designation under the Entity List, marking them as military end users subject to the BIS military end-use rule (§744.21). Five entities face the stricter outright denial policy with no license exceptions available.

Downstream implications

• Major disruption to Russian aerospace and naval procurement channels for US-origin

components, including avionics, electronics, and precision engineering goods

• Closes previously gray-area procurement routes through Gazprom Neft Shelf and other

state-adjacent entities with dual-use technology access

• Reinforces and complements the broader Russia/Belarus EAR sanctions framework published

simultaneously as corrections and clarifications (see companion rule 2022-06-06)

• Puts allied trading partners on notice of specific prohibited end users, facilitating

parallel enforcement by Wassenaar Arrangement members

Open questions

• Extent to which designated entities can circumvent through third-country procurement

(UAE, Turkey, China intermediaries)

• Effectiveness of footnote 3 restrictions vs. outright denial in limiting actual flows