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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 March 25, 2025, the Department of Commerce&rsquo;s Bureau of Industry and Security (BIS) added over 80 companies to its Entity List through two Final Rules. &nbsp;These are the first listings by BIS under President Donald Trump&rsquo;s second term and the listings heavily focus on China.&nbsp; According to BIS, these entities &ldquo;have been determined by the U.S. Government to be acting contrary to the national security or foreign policy interests of the United States.&rdquo;&nbsp; In a <a href="https://www.bis.gov/press-release/commerce-further-restricts-chinas-artificial-intelligence-advanced-computing-capabilities">press release</a>, BIS noted that the objectives for these listings are to:
<ul class="wp-block-list">
<li>Restrict the Chinese Communist Party&rsquo;s (CCP) ability to acquire and develop high-performance and exascale computing capabilities, as well as quantum technologies, for military applications;</li>
<li>Impede China&rsquo;s development of its hypersonic weapons program;</li>
<li>Prevent entities associated with the Test Flying Academy of South Africa (TFASA) from using U.S. items to train Chinese military forces;</li>
<li>Disrupt Iran&rsquo;s procurement of unmanned aerial vehicles (UAVs) and related defense items; and</li>
<li>Impair the development of unsafeguarded nuclear activities and the ballistic missile program in Pakistan.</li>
</ul>
In the first <a href="https://public-inspection.federalregister.gov/2025-05427.pdf">Final Rule</a>, BIS added 12 companies under the destinations of China (11) and Taiwan (1).&nbsp; These entities are being added to the Entity List due to: (i) &nbsp;acquiring or attempting to acquire U.S.-origin items in support of China&rsquo;s military modernization; (ii) acquiring or attempting to acquire U.S.-origin items in support of supercomputer projects for the Chinese government and/or military; or, (iii) involvement in the development of Chinese exascale supercomputers.&nbsp; Each of these entities will also be subject to restrictions on foreign-produced items made with U.S. technology.&nbsp; For all of these entities, a license is now required from BIS for all items subject to the Export Administration Regulations (EAR). &nbsp;License applications will be reviewed under either a presumption of denial or outright policy of denial.&nbsp; This rule was effective on March 25, 2025.
For the changes being made in this Final Rule, shipments of items removed from eligibility for a License Exception or export, reexport, or transfer (in-country) without a license (NLR) as a result of this regulatory action that were en route aboard a carrier to a port of export, reexport, or transfer (in-country), on March 25, 2025, may proceed to that destination until April 24, 2025. &nbsp;&nbsp;However, any such items not actually exported, reexported or transferred (in-country) before midnight, on April 24, 2025, require a license in accordance with this Final Rule.
In the second <a href="https://public-inspection.federalregister.gov/2025-05426.pdf">Final Rule</a>, BIS added 70 companies under the destinations of China (42); Iran (2); Pakistan (19); South Africa (3); and the United Arab Emirates (UAE) (4). These entities are being added to the Entity List due to: (i) their contributions to Pakistan&rsquo;s unsafeguarded nuclear activities; (ii) their contributions to Pakistan&rsquo;s unsafeguarded nuclear activities; (iii) acquiring or attempting to acquire U.S.-origin items in support of advancing China&rsquo;s quantum technology capabilities; (iv) links to or attempts to sell products to companies either on or that supply Entity List parties; (v) acquiring or attempting to acquire U.S.-origin items in support of China&rsquo;s military modernization; or (vi) attempts to circumvent export controls and sanctions to divert U.S.-origin technology and equipment to Iran.&nbsp; For all of these entities, a license is now required from BIS for all items subject to the Export Administration Regulations (EAR). &nbsp;License applications will be reviewed under a presumption of denial.&nbsp; This Final Rule is effective on March 28, 2025.
For the changes being made in this second Final Rule, shipments of items removed from eligibility for a License Exception or export, reexport, or transfer (in-country) without a license (NLR) as a result of this regulatory action that were en route aboard a carrier to a port of export, reexport, or transfer (in-country), on March 28, 2025, may proceed to that destination until April 27, 2025. &nbsp;However, any such items not actually exported, reexported or transferred (in-country) before midnight, on April 27, 2025, require a license in accordance with this Final Rule.

BIS Adds Over 80 Companies to Entity List, with Heavy Focus on China

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