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ARTICLE · 12 OCTOBER 2022

BIS Announces Significant Changes To How It Administers Unverified And Entity Lists

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Importantly, BIS amended the EAR to add a new criterion for placing a party on the Entity List: a sustained lack of cooperation by the host government to schedule and facilitate the completion of an end-use check of an entity identified on the Unverified List.

United StatesGovernment, Public Sector
Thomas McCarthy
Thomas McCarthy
Kevin Wolf
Kevin Wolf
Shiva Aminian
Shiva Aminian
Susan Kovarovics
Susan Kovarovics
Mahmoud Baki Fadlallah
Mahmoud Baki Fadlallah
Ragan Updegraff
Ragan Updegraff
Kimberly M Myers
Kimberly M Myers
Anne Borkovic
Anne Borkovic
Jaelyn Edwards Judelson
Jaelyn Edwards Judelson
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Key Points:

  • Importantly, BIS amended the EAR to add a new criterion for placing a party on the Entity List: a sustained lack of cooperation by the host government to schedule and facilitate the completion of an end-use check of an entity identified on the Unverified List.
  • In a policy memorandum that accompanied the new rule, BIS stated that it will add to the Unverified List any party that fails to complete a requested end-use check within 60 days of the request, and that it will initiate the interagency process for adding to the Entity List any party that fails to complete the end-use check within 60 days following the party's addition to the Unverified List if these failures are the result of a lack of cooperation by the host government.

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