US BIS Entity List: 28 Entities Added — China, Russia and Global Diversion Network (April 2023)
Export control↓ Restrictive~🇺🇸 US · BIS✎ 2026-05-14
announced 17 Apr 2023
effective 12 Apr 2023
principal 🇨🇳 CN🇷🇺 RU🇸🇾 SY
Status
effective 12 Apr 2023 · stage not filed
Sourcing
🟢 primary-OJ 1 primary
🇺🇸 US issued this export control measure targeting 10 jurisdictions, touching electronics, semiconductors, defence and 1 more sectors. It reads as restrictive.
RBI 3quant 5 · $796.05B (8/10 targets)📌 stable
Most-likely counter-response — historical base rate(reverse-direction responds_to: pairs; target country → issuer country)
🇨🇳 CN → 🇺🇸 US·median 434d (p25 351d · p75 516d · n=2)
Industrial policy 50%Export control 50%
Most-recent historical pairs
Base rate computed from analyst-asserted responds_to: edges in the reverse direction (target-country → issuer-country) for prior issuer-actions on the same target. Modal type + lag percentiles only — not a model output. Treat as a historical anchor for sizing counter-response scenarios, not a forecast in itself.
The Bureau of Industry and Security (BIS) added 28 entities under 32 entries to the Entity List effective April 12, 2023, targeting front companies and logistics networks attempting to evade US export controls to acquire US-origin items in support of Russia's military and defense industrial base. Twelve of the entities are Chinese electronics and semiconductor distributors operating as procurement intermediaries; ten are Russian logistics and trading firms; six are spread across Armenia, Malta, Singapore, Spain, Syria, Turkey, UAE, and Uzbekistan as diversion facilitators. All listed entities are subject to a license review policy of denial for virtually all EAR-controlled items.
Analyst notesShowHide
Mechanism
BIS published the final rule in the Federal Register on April 17, 2023 (FR Doc 2023-07840, 88 FR 23332), with an effective date of April 12, 2023. The rule amended Supplement No. 4 to Part 744 of the EAR to add 28 foreign entities — structured as 32 entries because several entities appear under multiple destination countries.
Country breakdown:
- China (12 entities): All are Hong Kong- or Shenzhen-based electronics and semiconductor component distributors. BIS determined each was attempting to acquire US-origin controlled items (microelectronics, printed circuit boards, electronic components) to supply Russia's military and defense industrial base, using Hong Kong as a transshipment node to circumvent the Russia-specific controls enacted in February 2022. Entities include 3HC Semiconductors, Allparts Trading, Avtex Semiconductor, ETC Electronics Ltd., Leadway Technology, Maxtronic International, Newsuntech Electronics, STK Electronics, Wynn Electronics, Xinnlinx Electronics, Yishang Network, and Yongli Electronic Components.
- Russia (10 entities): Logistics, trading, and broker firms facilitating Russian procurement of controlled goods since the invasion of Ukraine. Includes Art Logistics, GFK Logistics, Novastream, OOO Vest-Ost, Promelektronika, SKS Elektron Broker, TD Promelektronika, and Trust Logistics entities.
- Armenia (1), Malta (1), Singapore (1), Spain (1), Syria (1), Turkey (1), UAE (2), Uzbekistan (2): Mixed logistics, aviation-services, and trading entities. I JET GLOBAL DMCC (UAE) was designated for coordinating flights that assisted in transferring Iranian UAVs to Russia. Success Aviation Services FZC similarly provided aviation logistics for Iran-Russia UAV transfers. The Syrian and other entries represent diversion nodes in secondary supply networks.
All 28 entities are subject to a license review policy of denial for all items subject to the EAR, except EAR99 food and medicine items (case-by-case review with humanitarian exception available).
Downstream implications
- China-as-transshipment-hub pattern: The concentration of Chinese distributors in this list — a full 12 of 28 entities — established an early enforcement template that BIS expanded substantially in later rounds (June 2023, February 2024, August 2024). Compliance counsel at US electronics manufacturers began implementing enhanced due-diligence checks on Hong Kong distributors after this action.
- UAV-logistics designations: The I JET GLOBAL DMCC and Success Aviation Services designations for facilitating Iran-to-Russia UAV transfers represent the first direct intersection between the Russia-evasion enforcement thread and the Iran-UAV-Russia supply chain that became a distinct enforcement focus in subsequent BIS rulemakings.
- Ongoing Central Asia/Gulf diversion corridor: The Armenia, UAE, and Uzbekistan entries signal early attention to post-February 2022 diversion architecture through the South Caucasus, Gulf, and Central Asia — patterns that intensified dramatically in September–December 2023 entity list rounds.
Open questions
- Whether any of the 12 Chinese entities subsequently filed for delisting or sought license review; no public docket entries have been identified.
- The Malta entry was not separately identified by name in the summary text available; full entity name is in Supplement No. 4 of the Final Rule (88 FR 23332, p. 23333).