BIS adds 29 entries (26 entities, 3 addresses) to Entity List for diverting US-origin items to Iran

Mechanism

BIS amends EAR Supplement No. 4 to Part 744 by adding 26 entities and 3 addresses across China (19), Turkey (9), and the UAE (1). For every listed party, all items subject to the EAR — not just items on the Commerce Control List — require a BIS export, reexport, or in-country transfer license, with a presumption-of-denial review policy and no use of license exceptions permitted. The end-use justification cited in the rule is procurement-network diversion: the parties are alleged to have routed US-origin electronics and unmanned-aerial-vehicle (UAV) components into Iran, including onward to parties already on the Entity List and on OFAC's SDN List.

The rule is a Final rule (not interim), effective one day before publication (October 8, 2025), with the standard EAR savings clause for shipments already in transit on the effective date.

Downstream implications

• Tightens the secondary-perimeter around Iran's drone and military-electronics

programs — adds friction to the China→Hong Kong→Turkey→UAE→Iran diversion routes that have been the dominant work-around for direct Iran controls.

• Compliance burden falls on US distributors, semiconductor brokers, and

freight forwarders who now must screen against 29 new entries; tightens due-diligence expectations on transactions touching Turkey and the Greater Middle East trade corridor.

• The 19-China / 9-Turkey / 1-UAE split signals that BIS sees Turkey as a

growing diversion-hub jurisdiction — consistent with the broader 2024-25 enforcement pattern of Iran-procurement listings increasingly involving Turkish trading houses rather than only PRC counterparties.

• Final-rule (rather than interim) status indicates BIS treated the case

evidence as sufficient for immediate listing without notice-and-comment.

Open questions

• Whether any of the listed parties have observable trade-data footprints

(HS-code mix, port-pairs) that would let downstream consumers verify the diversion-route hypothesis quantitatively.

• Whether the Turkish entries overlap with parties already designated under

OFAC's Iran programs (which would put them in joint Entity-List + SDN status — the most restrictive combined posture).

• Whether the UAE single-entity addition is a free-zone trading company (the

typical UAE diversion-channel pattern) or a different structure.