The OverRuled: China Trade Controls Resource Center has been updated with the following actions:
- 12 Jun 2024 (BIS):
BIS released a final rule to enhance U.S. export control restrictions against Russia, with broader changes impacting future Entity List designations. This entry describes elements of the final rule that impact the PRC.
First, BIS created a new regulatory framework for listing addresses on the Entity List that present a high risk of involvement in unlawful diversion. BIS added eight Hong Kong addresses (under the destination of the PRC) associated with significant transshipment of sensitive goods to Russia in connection with this rule change. BIS stated that it has verified that these addresses are associated with a significant number of entities whose activities risk violating the EAR, including associations with parties on the Entity List or the Unverified List at the listed addresses.
Second, BIS separately added five entities to the Entity List, including four under the destination of the PRC, for the following reasons:
- Being involved in the shipment of controlled items to Russia since Russia's invasion of Ukraine in February 2022, as well as acquiring and attempting to acquire U.S.-origin items applicable to unmanned aerial vehicles ("UAVs") to be used by Chinese military entities; and
- Procuring components, including U.S.-origin components, that are used to develop and produce Shahed-series UAVs, which have been used by Russia in Ukraine.
Separately, BIS issued two Temporary Denial Orders ("TDOs") suspending the export privileges of two Russian procurement networks. One TDO covered four companies and one person in Hong Kong, among other parties. These parties were allegedly involved in a transnational scheme to circumvent U.S. export controls and export 260 shipments of mostly aircraft parts to Russia, including to Pobeda Airlines (which is also subject to a TDO).
- Being involved in the shipment of controlled items to Russia since Russia's invasion of Ukraine in February 2022, as well as acquiring and attempting to acquire U.S.-origin items applicable to unmanned aerial vehicles ("UAVs") to be used by Chinese military entities; and
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