On August 17, 2020, the U.S. Bureau of Industry and Security (“BIS”) issued a Final Rule clarifying the supplemental licensing requirements applicable to entities listed on the BIS Entity List. Pursuant to this change, additional licensing requirements will apply to all entities on the BIS Entity List whenever those listed entities are a party to a transaction subject to the Export Administration Regulations (“EAR”), and they act as the purchaser, intermediate consignee, ultimate consignee, or end-user.
In the Final Rule, BIS explains that “[p]rior to publication of this final rule, § 744.11 [of the EAR)] did not explicitly address circumstances in which a listed entity may be playing a role other than consignee or end-user in the transaction, e.g., a purchaser or intermediate consignee.”
This final rule serves the purpose of aligning the supplemental licensing requirements for entities on the BIS Entity List with the restrictions applicable to transactions involving persons listed on the Unverified List. This change became effective August 17, 2020.
The BIS Final Rule is accessible here.
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