Core Viewpoint - The U.S. Department of Commerce's Bureau of Industry and Security (BIS) has added 26 entities and 3 addresses to the Entity List, primarily targeting intermediaries in China and Hong Kong that procure U.S.-origin electronic components for Iran and its proxy organizations [1][6]. Group 1: Entities and Addresses Added - The list includes 16 Chinese companies and 3 addresses in Hong Kong, with a focus on disrupting networks that facilitate the procurement of U.S. electronic components for Iranian armed groups [1][2]. - The Hong Kong addresses are linked to previously sanctioned Iranian electronic supply networks, indicating that any entity registered at these addresses will face automatic licensing requirements for exports under EAR jurisdiction [2]. Group 2: Specific Companies Involved - The companies listed range from large global distributors like Arrow's subsidiaries in China and Hong Kong to various small and medium-sized technology and trading firms [3]. - Specific companies include Arrow China Electronics Trading Co., Ltd., Beijing Kevins Technology Development Co., Ltd., and Easy Fly Intelligent Technology Co., Ltd., which are implicated in the procurement of components found in drone wreckage used by Iranian proxies [3][4]. Group 3: Regulatory Implications - All listed entities and addresses will be subject to a "presumption of denial" licensing policy for all items subject to EAR, with most licensing exceptions no longer applicable [6]. - The BIS has reiterated the "50% rule," meaning any foreign entity that is directly or indirectly owned 50% or more by the listed entities will also be subject to the same licensing requirements [6]. Group 4: Broader Context and Historical Reference - The inclusion of Arrow's subsidiaries marks a significant shift from a previous situation in 2020 where Arrow was not listed despite being part of a draft list of entities [7][8]. - This change reflects a broader enforcement logic and potential shifts in U.S. policy regarding global supply chains and geopolitical tensions [8].
突发!美国商务部BIS将数家电子元器件分销商列入实体清单