Industrial Policy & Trade Monitor· 2663 actions· ✨ 89 recent

The Bureau of Industry and Security (BIS) added 42 entities under 44 entries to the Entity List, effective December 7, 2023. The majority — 28 entities in Russia — are sanctioned for procuring or contracting on behalf of Russia's defense sector, including avionics, military-grade drones, and military electronics. Fourteen additional entities across Armenia, Belarus, Belgium, Cyprus, Germany, Kazakhstan, the Netherlands, China, and the UAE were added for operating diversion and transshipment networks that supply U.S.-origin items to Russian military end-users. All listed entities face a license requirement for all EAR-controlled items with a presumption of denial.

The Bureau of Industry and Security (BIS) issued a final rule on 19 May 2023 strengthening existing Export Administration Regulations (EAR) sanctions against Russia and Belarus. The rule expands the Foreign Direct Product (FDP) rule — which applies EAR jurisdiction to foreign-made items produced with US technology or equipment — to cover the temporarily occupied Crimea region of Ukraine. It also revises controls targeting Iran's supply of unmanned aerial vehicles (UAVs) to Russia, closing loopholes identified in prior rounds of Russia-Ukraine-related export-control rulemaking.

MOTIE finalised the 31st amendment of the Public Notice on Trade of Strategic Items on 24 April 2023, effective 28 April 2023, adding 741 items to the Russia/Belarus situational-licence (상황허가) list. The added items span industrial machinery, petroleum and gas refining equipment, steel, chemicals, automotive goods and quantum computers judged to have high military-diversion potential. MOTIE stated the amendment brings Korea's export-control coverage of Russia/Belarus closer to that of the US, EU and Japan, incorporating 2022 international export-control-regime agreements and reflecting the US's 2nd-6th Russia sanctions rounds and a substantial part of the EU's measures.

The Bureau of Industry and Security (BIS) added 37 entities under 38 entries to the Entity List, effective March 2, 2023, spanning six destinations: China (28), Pakistan (4), Burma (3), Russia (1), Belarus (1), and Taiwan (1). The China tranche — the largest — targets entities supporting the People's Liberation Army's military modernization, including BGI Research and Forensic Genomics International (genomic surveillance/data risk), Inspur Group Co. Ltd. (cloud servers supplied to Chinese military), and Loongson Technology (domestic CPU developer). Three Burmese entities, including the Ministry of Transport and Communications, are designated for providing surveillance equipment enabling the military junta's tracking and targeting of civilians. Pakistani entities Abdul Razaq Asim, Add-On Technology, and Dynamic Engineers are added for contributing to Pakistan's ballistic missile programs; Russian DMT Electronics and Belarusian DMT Trading LLC for export-control evasion. All listed entities are subject to a license requirement for all items subject to the EAR, with the review policy being presumption of denial for the majority of Chinese entries.

The Bureau of Industry and Security (BIS) established a new Iran Foreign Direct Product (FDP) rule and created Supplement No. 7 to Part 746 of the EAR, effective 24 February 2023, to address Iran's supply of UAVs to Russia for use against Ukraine. The rule adds twelve HTS-6 codes covering UAV-relevant components — aircraft engines, processors, capacitors, memories, and radio navigation equipment — many of which are EAR99 items outside existing ECCNs, requiring a new licence for exports and reexports to Iran. Simultaneously, the rule expands the existing Russia/Belarus FDP rule to cover these same items, closing a gap where foreign-produced items derived from US technology could transit to Russia via Iran without triggering EAR licence requirements.

The Bureau of Industry and Security expanded EAR sanctions against Russia and Belarus effective 24 February 2023, adding 322 HTS-6 industrial items to Supplement No. 4 to Part 746 (oil-and-gas equipment, flat-rolled steel, pumps, turbines, marine and aviation engines) and 276 luxury goods to Supplement No. 5. Supplement No. 6 was amended to add biological and chemical-synthesis equipment including bioreactors, peptide synthesizers, and nucleotide reagents, targeting Russia's biodefence and dual-use procurement pathway. The rule also migrated Supplement No. 2 from Schedule B to HTS-6 identifiers to align with allied partner frameworks, added Taiwan to the list of countries excluded from licence requirements, and extended Section 744.7 end-use restrictions to cover in-country transfers inside Russia and Belarus.