Communications Litigation Today was a Warren News publication.

BIS Adds 24 Entities to Entity List

The Commerce Department Bureau of Industry and Security added 24 entities to its Entity List and revised five existing entries, the agency said in a notice. The new entries include companies in China, Iran, Pakistan, Russia and the United Arab Emirates; and the revised entries are for entities in France, Iran, Lebanon, Singapore and the United Kingdom. The changes take effect March 16. All shipments now requiring a license as a result of this rule that were on dock for loading or aboard a carrier to a port as of that date may proceed to their destinations under the previous eligibility, BIS said.

For shipments to the entities, BIS imposed a license requirement for all items subject to the Export Administration Regulations and imposed a review policy of presumption of denial for 20 of the 24 entities. BIS will employ a case-by-case review policy for shipments relating to the “safety of civil aviation” to Iran Air, but will impose a presumption of denial for all other license applications to the entity. For National Engineering Service Trading and Consultancy Company, Triton Educational Equipment & Consultancy Co and Advance Multicom, BIS imposed a “nuclear end-user and end-use based provision” license review policy.

Among the additions to the Entity List are China-based Wuhan IRCEN Technology and Jalal Rohollahnejad, which illegally procured goods for Rayan Roshd Afzar Company, a Specially Designated National. BIS also added Iran Air for transporting military-related equipment for Iran’s Islamic Revolutionary Guard Corps and defense ministry.

Other additions include Iran-based Aref Bali Lashak, Kamran Daneshjou, Mehdi Teranchi, Ali Mehdipour Omrani and Sayyed Mohammad Mehdi Hadavi and Pakistan-based National Engineering Service Trading and Consultancy Company, Triton Educational Equipment & Consultancy Co., Advance Multicom, Kepler Corporation and Samina Pvt. Ltd for involvement in nuclear-related activities. Also added were Pakistan-based United Engineering and Skytech Global Pvt. Ltd. for contributing to Pakistan’s missile program.

BIS added four other entities for attempting to illegally procure U.S.-origin items, including Pakistan-based SNTS Tech and SANCO Pakistan and UAE-based SANCO Middle East, FZC and SANCO Middle East, LLC. In addition, Russia-based Technomar and Avilon Ltd. acted on behalf of a listed entity to evade licensing requirements, while UAE-based Focus Middle East and Wellmar Technology FZE conspired to transship U.S.-origin goods to Iran.

Lastly, BIS added UAE-based Pegasus General Trading FZC for making “multiple attempts” to acquire U.S.-origin goods destined for Pakistan’s nuclear program. The company also provided false information to BIS during an end-use check and falsified official documents “to obfuscate the true end-users of items” subject to the EAR.

BIS revised three existing entries for Dart Aviation for destinations in France, Iran and the U.K. by correcting the spelling of an alias. BIS also corrected the spelling of an alias and removed “redundant text” for the Lebanon destination for EDO-ELEMED, and revised the alias of Singapore-based Hia Soo Gan Benson.