BIS Adds 13 Entities to Unverified List

What is Unverified List?

The Unverified List (UVL) is a list maintained by the Bureau of Industry and Security (BIS) within the U.S. Department of Commerce. It comprises the names and addresses of foreign individuals or entities engaged in transactions governed by the Export Administration Regulations (EAR), whose legitimacy and adherence to export control regulations could not be confirmed through end-use checks or post-shipment verifications.

Being listed in the Unverified List entails that transactions involving these entities undergo increased scrutiny and are subjected to additional restrictions. Exporters are required to exercise increased caution when engaging with parties on the UVL, which may involve obtaining a statement from them. In certain cases, exporters may also become ineligible for specific license exceptions. The purpose of this list is to mitigate the risk of exported items being diverted to prohibited end uses or end users.

Latest Additions to Unverified List

On December 19, 2023, the Bureau of Industry and Security (BIS) within the Department of Commerce issued a Final Rule that incorporated 13 new entities into its Unverified List (UVL). These entities are:

• Beijing Jin Sheng Bo Yue Technology Co., Ltd.;
• Beijing Shengbo Xietong Technology Co. Ltd.
• Fulian Precision Electronics (Tianjin) Co. Ltd.
• Guangzhou Xinwei Transportation Co. Ltd.
• Guangzhou Xinyun Intelligent Technology Co. Ltd.
• Nanning Fulian Fu Gui Precision Industrial Co. Ltd.
• Ningbo MOOF Trading Co. Ltd.
• Plexus (Xiamen) Co. Ltd.
• PNC Systems (Jiangsu) Co. Ltd.
• Shenzhen Bozhitongda Technologic Co. Ltd.
• Shenzhen Jia Li Chuang Tech Development Co. Ltd.
• Shenzhen Jingelang Co. Ltd.
• Xi'An Yierda Co. Ltd.

This list comprises foreign individuals or entities involved in transactions related to the export, reexport, or in-country transfer of items governed by the Export Administration Regulations (EAR). The inclusion of these entities on the UVL stems from BIS's inability to verify their bona fides through end-use checks or post-shipment verifications, raising concerns about the legitimacy of their involvement in such transactions and the potential risk of diversion to prohibited end uses or end users.

All 13 newly added entities are situated in China (listed below), and specific details, including names and addresses, can be found in the Final Rule. These additions took effect on December 19, 2023. Consequently, the use of license exceptions is suspended for transactions involving entities on the UVL. Exporters, re-exporters, and transferors must obtain a UVL statement from parties listed on the UVL before proceeding with relevant transactions.

However, shipments to these newly designated entities that were already in transit on December 19, 2023, based on actual orders for export, reexport, or in-country transfer to or within a foreign destination, can proceed under the previous eligibility for a License Exception or export, reexport, or transfer without a license (NLR), provided the items were exported from the United States before January 18, 2024.