Washington, D.C. (October 19, 2023) – On October 6, 2023, the Department of Commerce's Bureau of Industry and Security (BIS) amended the Export Administration Regulation (EAR) by adding 49 entities to the Entity List for their support of Russia's military and defense industrial base. The Entity List identifies entities that are believed to be involved, or pose a risk of becoming involved, in activities contrary to the national security or foreign policy of the United States. Once added to the list, these entities, and those who do business with them, are subject to licensing requirements and supplemental regulations.
Of these entities, 42 are based in the People's Republic of China. The remaining seven entities are spread across Estonia, Finland, Germany, India, Turkey, UAE, and the UK. In a press release issued last month wherein BIS announced these newest additions to the list, the entities were cited as supplying U.S.-origin integrated circuits to Russia. According to BIS, these circuits are an integral part of the missiles and drones Russia uses in its attacks on Ukrainian civilian targets.
In response to the sanctions, China's Ministry of Commerce criticized the U.S. for its "wrong practices," and suggested that the U.S. should "stop its unreasonable suppression of Chinese companies." However, BIS has made it perfectly clear that it will not hesitate to act against those who facilitate the sale of U.S.-origin technology to Russia's military. These newest additions to the Entity List come just days after BIS added 28 other entities to the List for their support of the Russian military, including the production of metal products and provision of components used to make unmanned aerial vehicles. For more information on these sanctions, see the Ukraine Conflict Response Group's previous alert here.
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