BIS Entity List: 24 Additions — Russia Defense Industry, Iran-Evasion Network, Pakistan/UAE Nuclear Proliferators

Mechanism

This final rule amends the Export Administration Regulations (EAR) under three separate enforcement clusters. All additions carry a presumption of denial for all EAR-controlled items (except EAR99 food and medicine); the License Review Policy applied is "Presumption of Denial" under 15 CFR Part 744 and Supplement No. 4.

Cluster 1 — Russia Defense-Electronics Network (Latvia, Russia, Switzerland)

Twelve entities are designated as "military end users" under 15 CFR §744.21 on the basis that they "significantly contribute to Russia's military and/or defense industrial base."

Russia (10 entities):

• Milandr Group — Russia's largest domestic microcontroller and ASIC designer.

Seven group entities are listed together: AO PKK Milandr, Milandr EK OOO, Milandr ICC JSC, Milur IS OOO, (OOO) Microelectronic Production Complex (MPK) Milandr, and the overarching AO Kraftway Corporation PSC (distributor). Milandr designs and manufactures radiation-hardened and military-grade chips for the Russian armed forces and state defence enterprises.

• AO Scientific Research Center for Electronic Computing — Russian military

electronics R&D institute.

• LLC Fibersense — Fiber-optic gyroscope and inertial navigation systems for

Russian military platforms.

• Ruselectronics JSC — Holding company for state-owned Russian radio-electronics

enterprises, part of Rostec.

• Scientific Production Company Optolink — Specialised optical components and

laser systems for defense applications.

Latvia (1 entity):

• Fiber Optic Solutions — Latvian intermediary that supported Russian procurement

of dual-use fiber-optic components for Milandr/Ruselectronics supply chains.

Switzerland (1 entity):

• Milur SA — Swiss affiliate of the Milandr group used to access Western

technology and components on behalf of the Russia defense microelectronics cluster.

Cluster 2 — Iran Evasion via Singapore Front Companies

Four Singapore-based companies are listed for having "supplied and/or attempted to supply items subject to the EAR" to Pardazan System Namad Arman (PASNA), an Iran-based entity designated as a Specially Designated National (SDN) under the Iran sanctions regime.

• Falcon Trading International Trading Company
• Hawk Electronic Supply
• Merlin Trading Company
• Pulse Tech International Company

These entities used Singapore's open trade regime to procure controlled electronics and re-export them to PASNA in violation of US Iran sanctions and EAR diversion controls. Singapore's role as a transit hub for Iran sanctions evasion had been flagged in prior BIS enforcement actions; this cluster reinforces the pattern.

Cluster 3 — Pakistan/UAE Unsafeguarded Nuclear and Missile Proliferation

Ten entities in Pakistan (6) and UAE (4) are designated for involvement in "unsafeguarded nuclear activities and missile proliferation-related activities."

Pakistan (6):

• Dynamic Engineering Corporation
• EnerQuip Private Ltd.
• NAR Technologies General Trading LLC (Pakistan branch)
• Rainbow Solutions
• TROJANS (Pakistan entity)
• Universal Drilling Engineers

UAE (4):

• Enerquip Limited (UAE entity)
• NAR Technologies General Trading LLC (UAE branch)
• TROJANS (UAE entity)
• Zain Enterprises FZE

Several of these entities appear in both country columns (NAR Technologies, TROJANS, Enerquip/EnerQuip), reflecting a cross-border procurement network using UAE free-zone structures to acquire dual-use equipment for Pakistan's unsafeguarded nuclear program. "Unsafeguarded" refers to facilities not subject to IAEA safeguard inspections under Pakistan's non-NPT status.

Removal

Safe Technical Supply Co., LLC was simultaneously removed from three existing entries (Oman, Saudi Arabia, UAE), consistent with a standard delisting upon compliance or enforcement resolution.

Downstream implications

• The Milandr group designations are among the most consequential Russia listings in the

2022 wave: Milandr chips are embedded in Russian missile-guidance systems, satellite equipment, and armoured-vehicle electronics. Cutting US-FDP-covered components from Milandr supply lines (including European and Asian suppliers using US fab equipment) materially constrains Russian domestic chip production for defense.

• The Switzerland listing (Milur SA) signals that BIS is tracing the Milandr network

through neutral-country intermediaries — a pattern that intensified through 2023-2024 with additional Swiss and Emirati shell-company designations.

• The Singapore cluster adds to a growing register of Southeast Asian front companies

used for Iran diversion. Singapore's government has since co-operated with BIS on export-control enforcement, but this action predates the formal MOU era.

• The Pakistan/UAE nuclear proliferation cluster is structurally distinct from the Russia

and Iran clusters: it targets entities supporting a state (Pakistan) whose nuclear program is entirely outside NPT safeguards, using UAE free-zone logistics as the procurement conduit.

Open questions

• Whether Swiss authorities pursued domestic enforcement against Milur SA following the

BIS listing, and whether the Swiss-SECO cooperation framework subsequently captured similar actors.

• The extent of PASNA's US-origin technology acquisition through the Singapore network

prior to listing, and whether follow-on enforcement actions identified additional intermediaries.

• Whether the Pakistan/UAE procurement network was disrupted or simply migrated to

unlisted intermediaries after the December 2022 designations.