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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 Unverified List (Supplement No. 6 to 15 CFR Part 744) lists foreign parties whose bona fides BIS has been unable to verify through end-use checks. Placement on the UVL suspends all EAR license exceptions for shipments to listed parties and requires US exporters to obtain a signed UVL Statement before exporting any EAR-subject item. Removal requires BIS to complete an end-use check confirming the entity is a legitimate and reliable end-user.
Two distinct removal rationales appear in this rule:
Cooperative removals (33 entities): BIS successfully completed end-use checks and verified the legitimacy of these parties. Heavy China concentration (27 of 33) reflects the ongoing backlog of end-use checks in China where host-government cooperation is intermittent. The October 7, 2022 BIS two-step escalation policy (UVL after 60 days of host-government non-cooperation → Entity List after a further 60 days) created a structured removal pathway for entities whose home governments ultimately cooperate.
Conforming removals (2 entities — Russia): OAO Radiofizika and Voentelecom JSC were removed from the UVL as a conforming change because they were simultaneously added to the Entity List, which carries a presumption of denial for all export license applications. Maintaining both UVL and Entity List placement would be redundant; the Entity List is the controlling restriction.
China (27): Beijing PowerMac Company; Beijing SWT Science; Beijing Zhonghehangxun Technology; Chongqing Xinyuhang Technology Co., Ltd.; Dandong Center for Food Control; DK Laser Company Ltd.; Guangdong Guanghua Sci-Tech Co.; Guangzhou GRG Metrology & Test (Beijing) Co., Ltd.; Gucheng Xian Fengxin Titanium Alloy; Hunan University; Jialin Precision Optics (Shanghai) Co., Ltd.; Jinan Bodor CNC Machine Co., Ltd.; Lishui Zhengyang Electric Power Construction; Luoyang Weimi Optics; Nanchang University; Nanjing Gova Technology Co. Ltd.; Qingdao Sci-Tech Innovation Quality Testing Co Ltd.; Shuang Xiang (Fujian) Electronics; Sino Superconductor Technology; Suzhou Chaowei Jingna Optoelectric Co.; Suzhou Sen-Chuan Machinery Technology Co., Ltd.; Tianjin Optical Valley Technology Co., Ltd.; TRI Microsystems; Wuxi Hengling Technology Co., Ltd.; Yunnan FS Optics Co., Ltd.; Yunnan Tianhe Optoelectronic Co., Ltd.; Zhuzhou CRRC Special Equipment Technology Co.
Indonesia (1): PT Smart Cakrawala Aviation
Pakistan (2): Seven Star Company; T.M.A. International
Russia (2 — conforming, escalated to Entity List): OAO Radiofizika; Voentelecom JSC
Singapore (1): Smart Cakrawala Aviation
Turkey (1): Odak Kimya
UAE (1): Recaz Star General Trading LLC
removed entities without a UVL Statement.
telecoms) face a stronger restriction regime under the Entity List: presumption of denial replaces the UVL's more limited license-exception suspension.
Bodor is a major Chinese laser-cutting equipment maker whose CNC systems have dual-use implications; CRRC's Special Equipment division supplies industrial transport equipment globally.
verification — both are state universities with active semiconductor and materials research programs that had been flagged.
BIS Assistant Secretary for Export Enforcement Matthew S. Axelrod stated that the removals demonstrate "the tangible benefit of cooperation" — parties that facilitated end-use checks had restrictions lifted. The China-heavy removal batch (27 of 33) is consistent with the backlog pattern under the October 2022 two-step policy: China-domiciled entities make up the majority of new UVL additions but are also the primary source of cooperative removals once verification is completed.
clearing the UVL of Russian entities by Entity-Listing those with confirmed defence links.
represents a dual-destination entity under common ownership.