Industrial Policy & Trade Monitor· 2675 actions· ✨ 91 recent

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.