[co-author: Oscar Theblin]
On December 21, the Bureau of Industry and Security (BIS) published a Military End User (MEU) list to further implement the military end user/end use (MEU) rule defined in Section 744.21 of the Export Administration Regulations (EAR). An EAR license is required to export or reexport to the listed entities a broad range of items subject to U.S. jurisdiction.
The list, which had been the subject of public reports last month, represents a first tranche of 103 entities with 58 from China and 45 from Russia. A majority of the entities listed are in the aerospace industry, although other industries are also represented. Additional parties may be added or removed from the list as further determinations are made by the End-User Review Committee, an interagency body comprised of the Departments of Commerce, Defense, Energy, State, and Treasury. The list is not exhaustive, and exporters must still conduct due diligence on other end users to determine whether an exp
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December 18, 2020 – On December 18, 2020,
the U.S. Department of Commerce, Bureau of Industry and Security
( BIS ) released a final rule that would add 77 new entities,
including Semiconductor Manufacturing International Corporation
Incorporated ( SMIC ), to the Entity List. All of the
newly added entities are subject to a license requirement for all
items subject to the Export Administration Regulations
( EAR ), even though some entities are subject to
different license review policies. Consistent with BIS s
clarification of the Entity List licensing requirements from
earlier this year, the license requirement will apply whenever any
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The U.S. Department of State announced that Sudan’s designation as a “State Sponsor of Terrorism” has been officially rescinded effective December 14, 2020. In October, the President notified Congress that Sudan’s designation would be rescinded and certified that Sudan had not provided support for acts of terrorism within the last six months, and that Sudan has provided assurances it will not support terrorism in the future. Until the Export Administration Regulations (“EAR”) are amended, however, items controlled under Export Control Classification Numbers (“ECCNs”) that are subject to anti-terrorism (“AT”) controls will still require a license for export or reexport to Sudan pursuant to the AT controls under Section 742.10 of the EAR. Once the Department of Commerce adopts those amendments to the EAR, it will be permissible to export or reexport AT-controlled ECCN items to Sudan without a license.