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

In its first major export-regulatory action of the second Trump administration, BIS amended the EAR to add 70 entities to the Entity List under the destinations of China (42), Iran (2), Pakistan (19), South Africa (3), and the United Arab Emirates (4), and modified four existing entries (France, Iran, Senegal, UK). New listings carry a license requirement for all items subject to the EAR with a presumption-of-denial review policy and no license exceptions available. Stated objectives include restricting China's acquisition of high-performance computing and quantum technologies for military use, impeding hypersonic-weapons development, disrupting Iran's UAV and defense procurement, and impairing Pakistan's unsafeguarded nuclear and ballistic-missile programs. The rule also targets the Test Flying Academy of South Africa for using U.S.-origin items to train Chinese military pilots.

The Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) by adding 13 entities under 13 entries to the Entity List, listed under the destinations of Burma (1), China (11), and Pakistan (1). The PRC additions concentrate on the optics/photonics, RF/microwave, and military-civil-fusion research-institute layer of China's military-modernization stack — including CAS Changchun Institute of Optics, Fine Mechanics and Physics (CIOMP), Shanghai Institute of Optics and Fine Mechanics (SIOM), Peng Cheng Laboratory, Ji Hua Laboratory, and the Yaguang/Chengdu RML defense-electronics cluster — with explicit references to support for hypersonic-weapons development. The Burma entity is Telecom International Myanmar (Mytel), added for providing surveillance services and financial support to the post-coup military regime; the Pakistan entity (Emerging Future Solutions Pvt Ltd) was added for contributions to Pakistan's ballistic-missile programme. All 13 entries carry a license requirement for all items subject to the EAR with a presumption-of-denial review policy and no license exceptions. The rule was effective on publication, January 6, 2025, with a savings clause through February 5, 2025 for goods already en route.

Premier Li Qiang signed State Council Decree No. 792 on 19 October 2024 promulgating the Regulations of the People's Republic of China on Export Controls for Dual-Use Items, with effect from 1 December 2024. The regulation, organised in six chapters and 50 articles, consolidates the previously fragmented nuclear / biological / chemical / missile dual-use control regimes into a single State Council framework operationalising the 2020 Export Control Law. It introduces a control-list / temporary-control / watchlist architecture, a statutory end-user / end-use commitment regime, transit / transhipment / re-export controls, extraterritorial reach over PRC items downstream, and explicit linkage to the Anti-Foreign Sanctions Law. On 15 November 2024 MOFCOM, MIIT, GAC and SCA jointly issued Announcement No. 51 of 2024 publishing the consolidated Dual-Use Items Export Control List with a unified five-character ECCN-style coding system, also effective 1 December 2024.

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) 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 added 24 entities across 26 entries to the Entity List, effective December 8, 2022, covering Latvia, Pakistan, Russia, Singapore, Switzerland, and the United Arab Emirates. Three distinct enforcement clusters are addressed: Russian defense-electronics firms and their foreign affiliates supporting Russia's military-industrial base post-Ukraine invasion; Singapore-based front companies that supplied controlled items to PASNA, an Iran-based Specially Designated National; and Pakistani and Emirati entities engaged in unsafeguarded nuclear activities and ballistic-missile proliferation. One entity (Safe Technical Supply Co., LLC) was simultaneously removed from three entries covering Oman, Saudi Arabia, and the UAE.

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 US Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) effective November 26, 2021, by adding 28 entries to the Entity List across China (12), Japan (1), Pakistan (13 including 2 individuals), Singapore (1), and Taiwan (1). Designations span three distinct threat clusters: (1) eight Chinese entities supporting military applications of quantum computing, including QuantumCTek Co. and the Hefei National Laboratory for Physical Sciences at Microscale; (2) approximately twelve Pakistani procurement entities and three Chinese suppliers facilitating Pakistan's unsafeguarded nuclear activities and ballistic missile program; and (3) the Corad Technology network across China, Japan, Singapore, and Taiwan that sold Western technology to Iran's military/space programs and North Korean front companies. Additionally, the Moscow Institute of Physics and Technology was added to the Military End-User (MEU) List for producing military products. All Entity List entries carry presumption-of-denial licensing policy with no exceptions available.