Industrial Policy & Trade Monitor· 2666 actions· ✨ 90 recent

The US Bureau of Industry and Security (BIS) removed nine Russian persons from the Unverified List (UVL) and simultaneously added them to the Entity List after the Russian government failed to facilitate end-use checks for more than 60 days — the first application of BIS's October 2022 escalation policy. All nine entities are subject to a license requirement covering all items subject to the EAR, with a policy of denial and no license exceptions available. The list spans electronics traders, state maritime infrastructure, defense R&D, microelectronics, and industrial equipment manufacturers.

The Bureau of Industry and Security amended the Export Administration Regulations by adding 34 entities under 43 entries to the Entity List, effective July 12, 2021. The largest cluster — 14 Chinese entities — comprises suppliers of surveillance infrastructure enabling the Chinese government's human-rights abuses in Xinjiang, including video analytics firms, network equipment makers, and geolocation platforms deployed in the Uyghur Region. Six Russian individuals and entities were added for participation in military procurement networks acquiring US-origin electronics and components in violation of the EAR. Additional listings cover Iran sanctions evaders (Canada, Lebanon), a UAE-based nuclear-proliferation facilitator, and one entity elevated from the Unverified List to the Entity List under China. All items subject to the EAR require a BIS licence to export, re-export, or transfer in-country to the listed parties, with a presumption-of-denial review policy.

Effective 17 August 2020 (published in the Federal Register 20 August 2020, Vol. 85 No. 162, FR Doc 2020-18213), BIS implemented three simultaneous measures targeting Huawei's global supply chain. First, 38 non-U.S. affiliates of Huawei Technologies Co., Ltd. were added to the Entity List with the most restrictive license review policy (presumption of denial) and designated under footnote 1, extending the Huawei-specific Foreign-Produced Direct Product Rule (FDPR) to their operations. Second, the Temporary General License (TGL), which since May 2019 had authorized limited ongoing transactions with Huawei (network maintenance, software updates, standards participation), was allowed to expire on 13 August 2020 and replaced with a narrower authorization. Third, BIS expanded the scope of the Huawei FDPR (General Prohibition Three) to cover foreign-produced items when a footnote 1 entity is a party to any transaction or when the item will be used in the production or development of products for any footnote 1 entity, closing the design-house loophole that had allowed TSMC to supply HiSilicon/Kirin chips as long as Huawei was not the direct importer.