Commerce Adds 80 Firms to Entity List

The U.S. Department of Commerce’s Bureau of Industry and Security (BIS) announced a final rule March 25th,  amending the Export Administration Regulations (EAR) by adding 80 foreign entities to the Entity List. Sales to listed entities are presumed denied and require an export license.

The additions, published in the Federal Register, target organizations in China (42), Pakistan (19), Iran (2), South Africa (3), and the United Arab Emirates (4) found to be acting contrary to U.S. national security or foreign policy interests. A follow-on rule adds (11) Chinese and one Taiwan entity related to exascale computing development.

Included in the release are seven affiliates of Inspur Group, which was added to the blacklist in 2023.  The Wall Street Journal notes that several of these Inspur-related entities assemble AI infrastructure components for Nvidia, designed for the Chinese and American markets. 

The rule, effective upon publication, also modifies existing entries for one entity, Dart Aviation, under the destinations of France, Iran, Senegal, and the United Kingdom.

Expanded Scope, Unchanged Structure

The new restrictions, while not altering the legal framework of the Export Administration Regulations (EAR), appear to chart a trajectory toward broader control measures. The EAR traditionally targets named entities, not their parent or subsidiary organizations—an approach long criticized as insufficient.

In a recent note Peter Jeydel and Ryan Last of Troutman Pepper write  “it is worth pausing and considering what this signals about the direction of export controls under this administration.”

The additions reflect a sharpening of U.S. export policy, particularly in restricting access to artificial intelligence (AI), quantum computing, and other sensitive technologies.

The EAR’s structure stands in contrast to the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC), which applies its sanctions through the “50% rule,” capturing all entities majority-owned by designated parties. The EAR does not yet incorporate such indirect ownership-based restrictions, a limitation “widely reported on for years.”

National Security Concerns Cited

The End-User Review Committee (ERC), which includes representatives from the Departments of Commerce, State, Defense, Energy, and Treasury, determined the listed entities are engaged in activities ranging from nuclear proliferation and missile development to quantum technology acquisition and military modernization efforts that conflict with U.S. security objectives.

Policy Direction

While the latest BIS action is consistent with prior efforts under the Biden administration, Troutman Pepper emphasizes that this development may preview “an intent to continue closing ‘loopholes’ in the EAR” and to expand the scope of U.S. export jurisdiction.

Proposals under consideration include extending controls to remote access of controlled software and hardware—a move that would significantly expand U.S. export control authority, though practical implementation concerns remain. “There are grave concerns within industry and government about how to craft this type of export control expansion and whether it would be workable,” the firm noted.

Implementation capacity may also be strained. Reports of career staff departures and possible funding cuts at BIS raise questions about how additional enforcement burdens will be managed. Despite these challenges, Secretary of Commerce Howard Lutnick recently pledged intensified enforcement but provided no specific regulatory roadmaps.

In Jeydel and Last’s assessment, “companies with exposure to China should be thinking about what may be next on this trajectory.” As the administration continues to prioritize national security concerns—particularly surrounding AI and defense-related technologies—additional regulatory expansion may follow.

Chinese Entities

In China, several entities were identified for efforts to acquire U.S.-origin items supporting quantum technologies with military applications. These include Scikro (Hong Kong) Instruments Limited and Scikro (Shanghai) Instrument Co., Ltd., noted for supplying dilution refrigeration equipment to defense-related institutions.

Entities such as the Aeronautics Computing Technique Research Institute, China Academy of Launch Vehicle Technology, and Xi’an-based microelectronics firms were cited for roles in China’s military-civil fusion and hypersonic weapons development.

Singleton (Suzhou) Electronics Technology Co., Ltd. and Suzhou SIP Hi-Tech Precision Electronics Co., Ltd. were added for their supply relationships with Huawei and HiSilicon, both already under U.S. export restrictions.

Pakistan Entities Linked to Nuclear and Missile Programs

Nineteen entities in Pakistan were added for contributions to unsafeguarded nuclear activities or ballistic missile development. Firms such as Britlite Engineering Company, IntraLink Incorporated, and Allied Business Concerns (Pvt) Ltd. were among those named. These entities now require licenses for all items subject to the EAR, with license applications to be reviewed under a presumption of denial.

Iran and China-Iran Proliferation Networks

Mohammad Reza Rajabi and Silk Road Trading Company Ltd., operating in both Iran and China, were added for attempting to procure U.S.-origin items for Iran’s defense and unmanned aerial vehicle programs. BIS found these entities used deceptive practices to evade existing export controls and sanctions.

Training of Chinese Military Forces

Entities in South Africa and the UAE were added due to their association with the Test Flying Academy of South Africa (TFASA), which was itself listed in June 2023. These entities—including Ascenso Aviation and TFASA Helicopter International—were found to support the training of Chinese military personnel using Western and NATO resources, including  Apache, Rooivalk, Merlin, Mi24 and Tiger helicopters, as well as various Agusta, Bell and Eurocopter products

Entity List Modifications

The rule also revises the entry for Dart Aviation across four jurisdictions by adding aliases and an address.

Regulatory Framework

The rules were issued under the authority of the Export Control Reform Act of 2018 (ECRA), which permits such actions without prior notice or public comment. Existing shipments affected by the rule may proceed under previous authorizations if exported within 30 days of publication.

“American technology should never be used against the American people. BIS is sending a clear, resounding message that the Trump administration will work tirelessly to safeguard our national security by preventing U.S. technologies and goods from being misused for high performance computing, hypersonic missiles, military aircraft training, and UAVs that threaten our national security,” said Under Secretary of Commerce for Industry and Security Jeffrey Kessler.

Additions and Modifications to the Entity List

Additions to the Entity List