Industrial Policy & Trade Monitor· 2667 actions· ✨ 89 recent

The U.S. Treasury's Office of Foreign Assets Control (OFAC) designated 10 individuals and entities in Venezuela and Iran on 30 December 2025 for facilitating Iran's proliferation of unmanned aerial vehicles (UAVs) and ballistic-missile inputs. Venezuela-based Empresa Aeronautica Nacional SA (EANSA) and its chair, Jose Jesus Urdaneta Gonzalez, were designated for negotiating directly with Iran's Qods Aviation Industries (QAI) and overseeing local assembly of QAI's Mohajer-series UAVs, re-branded in Venezuela as the ANSU series — an arrangement OFAC states has run since 2006. Separately, three Iran-based persons were designated for procuring sodium perchlorate, sebacic acid and nitrocellulose — precursor chemicals for ballistic-missile propellant and warhead production — on behalf of Parchin Chemical Industries (PCI), a unit of Iran's Defense Industries Organization (DIO). The action was taken under Executive Order 13382 (WMD proliferators and supporters) and Executive Order 13949 (Iran conventional-arms activities), in furtherance of National Security Presidential Memorandum 2.

The Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) by adding 18 persons to the Unverified List (UVL) and removing 5. Of the 18 additions, 5 are under China, 6 under Finland, 3 under Türkiye, 2 under Kazakhstan, 1 under Italy, and 1 under the United Kingdom — a geographic distribution dominated by Russia-adjacent diversion corridors. UVL placement does not impose a license-denial presumption (unlike the Entity List) but suspends use of EAR license exceptions for shipments to listed parties and requires US exporters to obtain a UVL Statement before exporting any item subject to the EAR. The rule was published and effective the same day, 25 April 2025 (90 FR 17339).

The Bureau of Industry and Security (BIS) amended the Export Administration Regulations by adding 8 entities to the Entity List under the destinations of Burma (2), China (2), and Russia (4), citing actions contrary to US foreign-policy interests, primarily enabling human-rights violations through aerial attacks on civilians (Burma), Uyghur surveillance (China), and facial-recognition targeting of protesters (Russia). All designated entities require licenses for all items subject to the EAR with a presumption of denial. The rule was effective immediately on publication, December 11, 2024.

Bureau of Industry and Security final rule (89 FR 84460, Doc 2024-24562) adding 26 entities to the Entity List across four destinations: six in China (aviation simulation for PLA modernisation; procurement for Iran WMD/UAV programs; evasive conduct), one in Egypt and three in the UAE (acquiring US civil aircraft parts for Russian buyers post-Ukraine invasion), and sixteen in Pakistan (nine front companies of Advanced Engineering Research Organization for Pakistan's cruise-missile and strategic-UAV programs, plus seven contributing to Pakistan's ballistic- missile program). The rule also removes two existing entries. All additions are licensed under a presumption-of-denial policy for all EAR-subject items.

The Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) by adding 8 persons to the Unverified List (UVL) and removing 2. Of the 8 additions, 3 are under China, 2 under Germany, 1 under Pakistan, and 2 under Türkiye. Of the 2 removals, 1 is under Saudi Arabia and 1 under China. UVL placement does not impose a license-denial presumption (unlike the Entity List) but suspends EAR license exceptions for shipments to listed parties and requires US exporters to obtain a signed UVL Statement before exporting any item subject to the EAR. The rule was published and effective the same day, 16 October 2024 (89 FR 83428, FR Doc 2024-23638).

A joint advisory issued January 26, 2024 by six US agencies (USTR, State, Treasury, Commerce, DHS, and Labor) updating businesses on supply-chain risks associated with Burma's post-coup military regime (SAC). The advisory warns of reputational, economic, and legal exposure for entities operating in or sourcing from Burma and specifically flags heightened due-diligence requirements for metal importers, the SAC's opaque network of corporate affiliates in Thailand, Singapore, India, and the UAE that complicate traceability, and cross-border reporting gaps for goods and funds transfers. Targeted sectors include rare earths (dysprosium, terbium), base metals and gold mining, timber, aviation services and jet fuel, computer chips and ICT equipment, and small arms components.

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) published a final rule (FR Doc 2023-18772; 88 FR 59927) amending 15 CFR 766.24 of the Export Administration Regulations (EAR) to create an additional option for the renewal of Temporary Denial Orders (TDOs). Under the new provision, BIS may request the Assistant Secretary for Export Enforcement renew a TDO for up to one year — rather than the standard maximum of 180 days — where the record demonstrates a pattern of repeated, ongoing, and/or continuous apparent violations. The rule was motivated by the sustained TDO enforcement campaign against Russian and Belarusian civil aviation entities that began in April 2022 following Russia's invasion of Ukraine.

The U.S. Treasury's Office of Foreign Assets Control (OFAC) issued a determination pursuant to Section 1(a)(i) of Executive Order 14014 identifying the jet fuel sector of the Burmese economy as a sanctions-eligible sector. The determination means that foreign persons who operate in Burma's jet fuel sector — including activities related to importation, exportation, reexportation, sale, supply, or transport of jet fuel in or involving Burma — may be designated and sanctioned by OFAC. Issued on the OFAC website on August 23, 2023 and formally published in the Federal Register on September 25, 2023 (FR Doc 2023-20713), the action was accompanied by concurrent SDN designations targeting key figures in the SAC junta's jet-fuel supply network.

The Bureau of Industry and Security (BIS) removed 35 persons from the Unverified List (UVL) effective 22 August 2023, spanning seven destinations: 27 entities in China, plus one each in Indonesia, Singapore, Turkey, and UAE; two in Pakistan; and two Russian entities removed as a conforming change after being escalated to the more restrictive Entity List. The 33 cooperative removals follow successful completion of end-use checks verifying each party's bona fides under §744.15(c)(2) of the EAR. Removal restores eligibility for EAR license exceptions and eliminates the UVL Statement requirement for US exporters shipping EAR-subject items to these parties.

BIS issued a correcting amendment to the EAR Entity List to add China Aviation Development Harbin Bearing Co., Ltd. — an AVIC subsidiary and specialist precision-bearing manufacturer — that was included in the preamble of the June 14, 2023 final rule (88 FR 38739) but inadvertently omitted from the regulatory text. The entity was designated for acquiring and attempting to acquire US-origin items in support of China's military modernization, including hypersonic weapons development, air-to-air missiles, and weapon lifecycle management using Western software. All EAR-subject items require a licence with a presumption of denial; retroactive effective date of June 16, 2023.

BIS published a final rule adding 43 entities under 50 entries to the EAR Entity List and removing one entity (Fiber Optic Solutions, Latvia), effective June 12, 2023. The additions span ten countries — China (31 entities), UAE (5), Pakistan (4), South Africa (3), UK (2), and one each in Kenya, Laos, Malaysia, Singapore, and Thailand — targeting four principal threat clusters: China's military modernization and hypersonic-weapons supply chain, an international network of flight-training academies (TFASA and affiliates) providing Western pilot training to Chinese military personnel, Pakistan-linked procurement for unsafeguarded ballistic-missile programs, and UAE/South Africa-based dual-use diversion networks. All listed entities require a BIS licence, with most subject to a presumption of denial.

The Bureau of Industry and Security (BIS) added eleven entities across Burma, China, Nicaragua, and Russia to the Entity List, effective March 28, 2023, under a human rights foreign policy rationale. Three Burmese trading companies and two Russian aviation-parts suppliers were designated for selling, procuring, and servicing military equipment enabling the Burmese military regime's attacks on civilians; five Xinjiang-based electronics manufacturers were added for activities contrary to U.S. foreign policy interests; and the Nicaraguan National Police was designated for serious human rights abuses. The rule simultaneously codified in the EAR that protection of human rights worldwide is an explicit basis for Entity List designations — a precedent-setting regulatory amendment extending the existing national-security and foreign-policy framework.

The Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) by adding 32 persons across 13 countries to the Unverified List (UVL) on the basis that BIS was unable to verify their bona fides through end-use checks. The largest concentration is in China (14 entities), followed by the UAE (5) and Turkey (4), with single entries in Bulgaria, Canada, Germany, Indonesia, Israel, Malaysia, and Singapore. UVL placement suspends EAR license exceptions for shipments to listed parties and requires US exporters to obtain a signed UVL Statement and file Electronic Export Information in the Automated Export System before shipping any item subject to the EAR. Published 24 March 2023 (88 FR 17706, FR Doc 2023-06171); effective 24 March 2023.

The Bureau of Industry and Security (BIS) added 76 Russian entities to the Entity List effective February 24, 2023, spanning three rationale categories: (1) biometric surveillance technology enabling Russian filtration operations in occupied Ukraine; (2) illicit acquisition of U.S.-origin controlled items; and (3) the Russian military-industrial complex encompassing missiles, aviation, shipbuilding, semiconductors, telecom, and defense electronics. All 76 entities are subject to a license requirement for all EAR-subject items with a presumption of denial; 66 entities receive footnote-3 designation as Russian military end-users, subjecting them to the Russia/Belarus Military End-User Foreign Direct Product Rule under §734.9(g). Four existing Entity List entries were simultaneously revised with additional aliases and tightened to a policy of denial. Notable designations include KAMAZ, the Skolkovo Foundation, Skoltech, Ilyushin Aviation Complex, and the State Missile Center Named After Akademika V.P. Makeyev.

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.

The Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) by adding seven Iranian entities to the Entity List effective 31 January 2023, for contributing to Russia's military and defense industrial base through the production and transfer of Iranian unmanned aerial vehicles (UAVs) used by Russia in Ukraine. The entities — including Shahed Aviation Industries, Qods Aviation Industry, and arms of the Islamic Revolutionary Guard Corps — are subject to a license requirement with a presumption of denial for all EAR-jurisdiction items. The rule applies the Russia/Belarus Military End User Foreign Direct Product (FDP) rule to all seven entities, extending its reach to foreign-produced items destined for or routed through these Iranian UAV producers.

The Bureau of Industry and Security added 57 entities under 57 entries to the Entity List, effective September 30, 2022, in direct response to Russia's ongoing invasion of Ukraine and its illegal annexation of Ukrainian regions. Of the 57 entities, 56 are listed under Russia and one (Subsidiary Sevastopol Naval Plant of Zvezdochka Shipyard) under the Crimea Region of Ukraine. The additions span aviation repair and overhaul facilities, aerospace R&D institutes, naval propulsion, ballistic-missile producers, advanced-materials and quantum science institutes, and the federal metrology agency; 50 of the 57 receive footnote 3 designations as Russian military end users, subjecting them to the Russia/Belarus-Military End User Foreign Direct Product Rule. All are added with a license review policy of denial for all EAR-subject items except food and medicine designated EAR99.

The Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) by adding China National Offshore Oil Corporation Ltd. (CNOOC) to the Entity List on the basis of its involvement in the PRC's unlawful maritime claims in the South China Sea and efforts to intimidate and coerce other South China Sea coastal states. In the same rule, Beijing Skyrizon Aviation Industry Investment Co., Ltd. was added to the Military End-User (MEU) List, while two Russian entities (Vsmpo-Avisma and Molot Oruzhie) were removed from the MEU List as duplicate entries. The rule took effect January 14, 2021, one day before publication in the Federal Register.