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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.
Standard Entity List perimeter expansion under 15 CFR Part 744, Supplement No. 4. All 11 new entries carry an "all items subject to the EAR" license requirement with a policy of presumption of denial and no license exceptions available. The rule proceeds in two distinct rationale clusters:
The dominant and most operationally significant tranche. BIS designated six entities for acting as part of a network to procure US-controlled aerospace and dual-use components for the Iran Aircraft Manufacturing Industrial Company (HESA) in Iran. HESA manufactures the Shahed-series one-way attack drones that Iran has supplied to Russia and that Russia has deployed extensively against Ukrainian civilian infrastructure, as well as against oil tankers in the Red Sea and Gulf of Oman.
Russia (3 entities):
and power converters for supersonic aircraft. Designated for procuring components feeding the Shahed UAV powertrain.
Designated for channelling controlled items to HESA via the Russian aerospace-services sector.
gas-turbine engine control systems. Designated for supplying UAV propulsion- adjacent components into the HESA supply chain.
UAE (2 entities):
the US to Iran through UAE-based trade channels.
diversion network as Khalaj Trading; named alongside the corporate entity.
China (1 entity in this cluster):
Russia/UAE entities for procuring dual-use UAV-applicable components for the HESA/Shahed supply chain.
The remaining five China entities were designated for attempting to acquire US-origin items to support China's military modernisation programme:
items for PRC military end-use.
a major Chinese drone-motor manufacturer; designated for acquiring controlled items under military end-use conditions. T-MOTOR is a top-tier global supplier of brushless motors, ESCs, and propellers to commercial UAV platforms; its designation marks the first time a leading civilian-drone- components brand of this scale was placed on the Entity List.
military-intelligence end-users.
military end-use conditions.
US-origin items for PRC military modernisation purposes.
The rule also adds one new alias to the existing entry for Shanghai Biren Intelligent Technology Co., Ltd. (GPU/AI-chip designer, previously listed for supporting PRC military AI ambitions). No other parameters of the Biren entry were altered.
This final rule is the first Entity List action published after BIS implemented the "50 Percent Rule" (the policy that entities owned ≥50% by an already-listed entity are themselves subject to EAR controls without a separate listing). The rule's preamble was read by export-control counsel as clarifying that BIS would continue to use formal Entity List additions even for 50%-rule-capturable subsidiaries when it wanted public designation precedent — a procedural clarification that shaped subsequent Entity List filing practice.
front against the HESA/Shahed component supply chain, supplementing the concurrent OFAC/SDN approach to Iran's drone programme. Subsequent entity list actions in the register (including the August 2024 123-entity rule) continued building out the Russia–Iran–China procurement-network perimeter.
established that leading civilian-use drone-component OEMs are not insulated from Entity List action if they supply military end-users. This precedent is directly relevant to SMH (semiconductor supply chain) and to ETFs with emerging-market industrial holdings.
Khalaj Amirhosseini confirmed the UAE as an active transit jurisdiction for Iran-bound CCL items — reinforcing the pattern visible in the October 2024 26-entity rule (which also hit UAE-based Iran-diversion networks).
ODK-Star were the sole Russian aerospace nodes or part of a wider ring that subsequent BIS actions addressed.
distributors) has been materially disrupted, or whether third-country intermediaries substituted for US-origin components post-designation.
continued to issue formal Entity List rules rather than relying on the automatic 50% coverage, suggesting the rule functions more as a public deterrent than an enforcement shortcut.