BIS CFR Correction restores Entity List entries for Kapil Raj Arora (Netherlands) and Orion Eleven Pvt. Ltd. (Pakistan)

Mechanism

This is a CFR Correction issued by the Office of the Federal Register on behalf of BIS. The annual revision of Title 15 of the Code of Federal Regulations had dropped two existing Entity List entries; this notice restores them so the published CFR matches the operative Entity List.

The restored entries are:

• Kapil Raj Arora, Netherlands — addresses at Breukelensestraat 16,

2574 RC, The Hague, and Knobbelswaansingel 19, 2496 LN, The Hague. License requirement: all items subject to the EAR; license review policy: presumption of denial.

• Orion Eleven Pvt. Ltd., Pakistan — license requirement: all

items subject to the EAR; license review policy: presumption of denial.

Because both parties were already on the Entity List operationally, exporters acting on a current EAR-compliant screening list were already treating them as restricted. The legal effect of the correction is to bring the published CFR into alignment with the operative list.

Downstream implications

• No new trade-flow impact: the entries were operationally in force

before this correction.

• Useful as a calibration data-point for how BIS resolves CFR/Entity

List divergence (technical correction rather than re-promulgation).

• The Pakistan entry sits inside the broader BIS Pakistan

diversion-concern perimeter — the same posture that drove the November 2024 Pakistan-specific export-control package.

Open questions

• Specific end-use basis (WMD/missile proliferation, military, or

procurement-network intermediary) for each entry — not restated in the correction notice; would need to be recovered from the original Entity List addition rule for each party.