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Key Updates to the BIS Entity List

Washington, D.C. (October 6, 2023) - On September 27, 2023, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) added 28 new entities to its Entity List through amendments to the Export Administration Regulations (EAR). Among these listed entities is Russian corporation VSMPO-AVISMA, the world’s largest titanium producer.

The BIS Entity List limits — and imposes licensing requirements on — export, reexport, and in-country transfer transactions with listed entities. VSMPO-AVISMA was designated on this list as a “military end user,” determined to be directly involved in the production and manufacture of titanium and other metal products for the Russian military. This listing and designation imposes license requirements for all items that are subject to the EAR, as well as a license review policy of denial. Consequently, future transactions with VSMPO-AVISMA will be severely restricted, with significant implications on exports and reexports of titanium.  Also, it is important to note that this is the second time VSMPO-AVISMA has been subjected to sanctions (In December 2020, the company was included in the sanction list due to its connections with the Russian Armed Forces).

The 27 other entities include companies from Russia, China, Finland, Germany, Oman, Pakistan, and the United Arab Emirates. The four other listed Russian companies are Device Consulting, Grant Instrument, SMT-iLogic, and Streloy, each of which has been "implicated in a conspiracy to violate US export controls, including a scheme to supply the Special Technology Center, an entity on the BIS Entity List, with components to make unmanned aerial vehicles (UAVs) for Russia's Main Intelligence Directorate of the General Staff (GRU)." Each of these companies are subject to heightened licensing requirements.

Lewis Brisbois’ experienced attorneys are prepared to support businesses in navigating the ever-evolving regulatory landscape of U.S. sanctions regulations. For more information, please contact the authors of this alert or other members of the Ukraine Conflict Response Group.

Authors:

Michael Gnesin, Partner

George Leahy, Law Clerk

Editors:

Jane C. Luxton, Managing Partner - Washington, D.C.

Andrew Pidgirsky, Partner & Chair of Ukraine Conflict Response Practice

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