Sep

19

And the Winner Is . . .


Posted by at 2:47 pm on September 19, 2008
Category: General

Flags. . . the United Arab Emirates. With the publication today by the Bureau of Industry and Security (“BIS”) of the additions to the Entity List announced on Wednesday, the UAE moves into first place in terms of the single country with the most entries on the Entity List. The tiny emirate, just a short boat-ride from Iran, now has 36 entries on the Entity List after today’s addition of 34 more companies and individuals.

By today’s action BIS added 108 entities to the list, 33 of which were already on General Order No. 3, Because of the transfer of those entities from General Order No. 3 to the Entity List, that general order is now being repealed and removed from Supplement No. 1 to Part 736 of the Export Administration Regulations. Entities that were previously listed in General Order No. 3 are designated with asterisks.

Entities from a total of thirteen countries were named to the Entity List. Those countries were Canada (2), PRC (3), Egypt (3), Germany (4), Hong Kong (19), Iran (25), Kuwait (2), Lebanon (2), Malaysia (14), Singapore (3), South Korea (1), Syria (3), UAE (34). (Seven entities were located in two countries, which accounts for the total of 115 new entries shown in the preceding list.)

A license is required for all exports to, or involving, any individual or country on the Entity List. No license exceptions are available for such exports, and BIS will apply a policy of denial to license requests.

As of time this entry was posted, BIS had not yet updated the “List to Check” portion of its website to reflect the new additions.

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Copyright © 2008 Clif Burns. All Rights Reserved.
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One Comment:


OKAY, lets all agree that I’m having a senior moment, but, even if we assume that the EAA had not expired 7 years and four Congresses ago, even if we ignore the language in Regan v. Wald to the effect that a change in the Cuban regulations would not have been authorized by IEEPA without a declaration of national emergency had those “authorities” not been grandfathered in, just what is the statutory authority for the Entities List and such an expansion of it without a declaration of national emergency?

Comment by Mike Deal on September 20th, 2008 @ 1:47 pm