BIS publishes revised Supplement 6 to Part 744 of the EAR (the “unverified list.”)

In today’s Federal Register, the Bureau of Industry and Security published a newly amended Supplement 6 to Part 744 listing 29 companies on the unverified list (UVL). In a previous trade alert posted on this blog (dated January 24, 2014) we advised our clients of new regulatory changes that apply to export dealings with companies listed on the UVL. Specifically, effective with the publication today of the newly released unverified list (supplement 6 to Part 744), no license exceptions can be used if your transaction includes a company listed on the UVL. In addition, AES filings are required for ALL shipments (whether they require a license or not of any value) that involve companies listed on the UVL. Finally, a special UVL statement is required before proceeding with exports, re-exports or transfers involving persons listed on the UVL. The current UVL includes persons/entities located in China, Hong Kong, Russia and the United Arab Emirates. For more information regarding background to the unverified list (i.e. why it exists), screening against the UVL and compliance with the new regulations covering dealings with UVL listed companies, please contact TSI global Consulting at 210-757-0618.

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