BIS Bars Aircraft's Parts and Chips Suppliers, Okays Chinese Lab

Aircraft parts suppliers to the Maduro Regime and Indian semiconductor distributors trading with Russia were the subject of regulatory actions last week, while Uncle Xi's promise of help with our Fentanyl problem got a state forensic lab off the blacklist.

Aircraft Parts to Venezuela

The ERC determined to add Aerofalcon S.L., under the destination of Spain; Novax Group S.A., under the destinations of Costa Rica, Ecuador, Panama, Venezuela, and Russia; and Zero Waste Global SA, under the destinations of Panama and Venezuela, to the Entity List.

These entities were used by their principals to circumvent U.S. sanctions, supplying the representatives of Nicolás Maduro in Venezuela with U.S. origin aircraft parts. This circumvention was conducted by, among other efforts, concealing the true end user and end destination of the exports using misrepresentations and fraudulent documents, including the filing of false Electronic Export Information.

These entities will be added with a license requirement for all items subject to the EAR and a license review policy of presumption of denial.

Indian Chip Sales to Russia

The ERC determined to add Si2 Microsystems Private Limited, under the destination of India, to the Entity List. This entity is added to the Entity List for providing support to Russia’s military and/or defense industrial base. Specifically, this entity supplied Russian consignees connected to the Russian defense sector with U.S.-origin integrated circuits after March 1, 2023. These integrated circuits are classified under Harmonized Tariff System (HTS)-6 codes 854231, 854232, 854233, and/or 854239. These HTS-6 codes are identified under supplement no. 4 to part 746 (Russian and Belarusian Industry Sector Sanctions Pursuant to § 746.5(a)(1)(ii)). All U.S.-origin items classified under these HTS-6 codes have been controlled for export and reexport and transfer within Russia since September 15, 2022. Such U.S.-origin items require a license under § 746.5(a)(1)(ii) of the EAR when destined to Russia or Belarus.1

Therefore, the documented shipments by this entity to Russia of such U.S.-origin items are contrary to U.S. national security and foreign policy interests under § 744.11(b) of the EAR. This entity will be added with a license requirement for all items subject to the EAR and a license review policy of denial.

 Earlier in the week the BIS Removed an entity from the entity list after review: 

Chinese Police Lab Removed From the Entity List

Reuters reports the Biden administration on Thursday removed the Chinese Ministry of Public Security's Institute of Forensic Science from a trade sanction list, part of a bid to convince Beijing to do more to halt the flow of the synthetic opioid fentanyl into the United States.

Washington put the institute on the list in 2020 over alleged abuses against Uyghurs and other minority groups, effectively barring it from receiving most goods from U.S. suppliers.

The ERC determined to remove the Ministry of Public Security's Institute of Forensic Science of China from the Entity List "pursuant to a removal proposal and review that the ERC conducted in accordance with procedures described in supplement no. 5 to part 744 of the EAR. Prior to removal from the Entity List by this rule, the Ministry of Public Security's Institute of Forensic Science of China was listed under the destination of China," according to BIS.

Additions to the Entity List

Entity List Removal


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