BIS Adds 11 to Entity List for Procuring Controlled Items for Iran, China, Russia

The Bureau of Industry and Security added 11 parties to its Entity List this week for procuring items to support Iranian drone programs, China’s military modernization efforts or Russia’s military. The additions, outlined in a final rule released April 10 and effective April 11, include technology companies, logistics firms and one person based in either China, Russia or the United Arab Emirates.

Several of the entities have tried to acquire U.S.-origin items to support Chinese military modernization, including military-intelligence end users in the country, BIS said. They include China-based LINKZOL (Beijing) Technology Co., Ltd.; Xi’an Like Innovative Information Technology Co., Ltd.; Beijing Anwise Technology Co., Ltd.; and SITONHOLY (Tianjin) Co., Ltd., which will all be subject to license requirements for all items subject to the Export Administration Regulations. Those companies also will face a license review policy of presumption of denial.

BIS also added China-based Jiangxi Xintuo Enterprise Co. Ltd. and designated it as a Russian or Belarusian military end user, subjecting it to license restrictions under the agency’s Russia/Belarus-Military End User Foreign Direct Product rule. The company has helped to procure unmanned aerial vehicles for Russia’s military, BIS said, and will face a license review policy of denial for all items subject to the EAR, except for food and medicine designated as EAR99, which will be reviewed on a case-by-case basis.

The agency also added China-based Shenzhen Jiasibo Technology Co., Ltd. and Russia-based Aerosila JSC SPE, Delta-Aero LLC, and JSC ODK-Star for working as a part of a network to procure aerospace parts, including dual-use items used in UAVs, for the Iran Aircraft Manufacturing Industrial Company. BIS said these parts help make Shahed-series drones that Iran uses to attack oil tankers in the Middle East and that Russia has used in its war against Ukraine.

BIS designated each of those entities as a Russian or Belarusian military end user, and they will also face a license review policy of denial for all items subject to the EAR apart from EAR99 food and medicine.

Dubai-based Khalaj Trading LLC and Mahdi Khalaj Amirhosseini were added to the Entity List for shipping export-controlled items from the U.S. to Iran through the UAE. BIS said the exports violated the Iranian Transactions and Sanctions Regulations, and they both will be subject to a license requirement for all items subject to the EAR. Licenses will be reviewed under a policy of presumption of denial.

All exports that now require a license as a result of this rule but were aboard a carrier to a port as of April 11 may proceed to their destinations under the previous eligibility as long as the items are exported before May 13, BIS said. Any items not exported before midnight May 13 will require a license.