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Thompson Hine LLP, a full-service business law firm with approximately 400 lawyers in 11 offices, was ranked number 1 in the category “Most innovative North American law firms: New working models” by The Financial Times and was 1 of 7 firms shortlisted for The American Lawyer’s inaugural Legal Services Innovation Award. The firm has been recognized by the National Law Journal as a Legal Technology Trailblazer and featured by Bloomberg for its innovative service delivery models, which drive accuracy and predictability. The firm’s commitment to innovation is embodied in Thompson Hine SmartPaTHTM – a smarter way to work – predictable, efficient and aligned with client goals. For more information, please visit ThompsonHine.com and ThompsonHine.com/SmartPaTH.

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On November 26, 2021, the Department of Commerce&rsquo;s Bureau of Industry and Security (BIS) published a <a href="https://www.govinfo.gov/content/pkg/FR-2021-11-26/pdf/2021-25808.pdf" target="_blank" rel="noopener">Final Rule</a> in the Federal Register adding 27 foreign entities and individuals to the Entity List for engaging in activities that are contrary to the national security or foreign policy interests of the United States. These entities and individuals are located in the People&rsquo;s Republic of China, Japan, Pakistan and Singapore, as follows:
China
<ul>
<li>Corad Technology (Shenzhen) Ltd.</li>
<li>Hangzhou Zhongke Microelectronics Co., Ltd.</li>
<li>Hefei National Laboratory for Physical Sciences at Microscale</li>
<li>Hunan Goke Microelectronics</li>
<li>New H3C Semiconductor Technologies Co., Ltd.</li>
<li>Peaktek Company Ltd.</li>
<li>Poly Asia Pacific Ltd., (PAPL)</li>
<li>QuantumCTek Co., Ltd.</li>
<li>Shaanxi Zhi En Electromechanical Technology Co., Ltd.</li>
<li>Shanghai QuantumCTek Co., Ltd.</li>
<li>Xi&rsquo;an Aerospace Huaxun Technology</li>
<li>Yunchip Microelectronics</li>
</ul>
&nbsp;Japan
<ul>
<li>Corad Technology Japan K.K.</li>
</ul>
&nbsp;Pakistan
<ul>
<li>Al-Qertas</li>
<li>Asay Trade &amp; Supplies</li>
<li>Broad Engineering (Pakistan)</li>
<li>Global Tech Engineers</li>
<li>Jade Machinery Pvt. Ltd.</li>
<li>Jiuding Refrigeration &amp; Air-conditioning Equipment Co (Pvt) Ltd.</li>
<li>K-SOFT Enterprises</li>
<li>Muhammad Ashraf</li>
<li>Muhammad Farrukh</li>
<li>Prime Tech</li>
<li>Q&amp;N Traders</li>
<li>Seljuk Traders (SMC-Private) Limited</li>
<li>U.H.L. Company</li>
</ul>
&nbsp;Singapore
<ul>
<li>Corad Technology Pte Ltd.</li>
</ul>
Eight of the Chinese entities were added to the Entity List in an effort to prevent U.S. emerging technologies from being used for China&rsquo;s quantum computing efforts that support military applications. Sixteen Chinese and Pakistani entities and individuals were added to the list due to their contributions to Pakistan&rsquo;s unsafeguarded nuclear activities or ballistic missile program. Three affiliates of Corad Technology Limited (a Chinese entity placed on the Entity List in 2019) have been added due to their involvement in sales of technology from the United States to Iran&rsquo;s military and space programs, Democratic People&rsquo;s Republic of Korea (North Korea) front companies, and Chinese government and defense industry subordinate entities.
Placement on the Entity List means that all exports, re-exports, or transfers of items subject to U.S. Export Administration Regulations (EAR) require a license from BIS, regardless of whether a U.S. person is involved in the transaction or whether the transaction involves the U.S. financial system. BIS has imposed a license review policy of a &ldquo;presumption of denial&rdquo; for these entities. In addition, no license exceptions are available for exports, reexports, or transfers (in-country) to these entities.
BIS also added the Moscow Institute of Physics and Technology to the Military End-User (MEU) List due to its production of military products for a military end-user. Placement on the MEU List places a requirement for a license for specific export, reexports or transfers (in-country) due to an &ldquo;unacceptable risk of use in or diversion to a &lsquo;military end use&rsquo; or &lsquo;military end user&rsquo;&rdquo; in Russia. BIS has imposed a license review policy of a presumption of denial for this Russian entity. In addition, no license exceptions are available for exports, reexports, or transfers (in-country) to this entity for items specified in <a href="https://www.bis.doc.gov/index.php/documents/regulations-docs/2343-part-744-control-policy-end-user-and-end-use-based-2/file" target="_blank" rel="noopener">Supplement No. 2 to Part 744</a> of the EAR.
This final rule was effective as of November 26, 2021. However, shipments that were en route aboard a carrier to a port of export, reexport, or transfer (in-country) on November 26, 2021, pursuant to actual orders for export or reexport to a foreign destination, may proceed to that destination under the previous eligibility for a license exception or export, reexport, or transfer (in-country) without a license (NLR).

BIS Adds 27 Entities to the Entity List and One Entity to the MEU List

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