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Commerce Adds Four To Entity List Related To Circumvention Of U.S. Sanctions Against Venezuela, Russia
The BIS adds Aerofalcon S.L., Novax Group S.A., Zero Waste Global SA, and Si2Microsystems Private Limited to the Entity List for activities against U.S. national security and foreign policy interests, related to circumventing sanctions against Venezuela and Russia.
WASHINGTON, D.C. – On Friday, the Commerce Department’s Bureau of Industry and
Security (BIS) released a rule adding four entities to the Entity List.
Aerofalcon S.L., under the destination of Spain; Novax Group S.A., under the destinations of
Russia, Venezuela, Panama, Ecuador, and Costa Rica; and Zero Waste Global SA, under the
destinations of Panama and Venezuela, are being added for engaging in activities contrary to
U.S. national security and foreign policy interests.
In addition, Si2Microsystems Private Limited, under the destination of India, is added to the
Entity List for providing support for to Russia’s military and/or defense industrial base.
“Restricting entities seeking to undermine our export controls from obtaining U.S.-origin items is
a crucial part of protecting our national security,” said Under Secretary of Commerce for
Industry and Security Alan Estevez. “We will use all of the tools at our disposal to ensure that
critical U.S. technology is safeguarded.”
“This action lists parties, in countries across the globe, who circumvent our controls,” said
Assistant Secretary of Commerce for Export Enforcement Matthew S. Axelrod. “We will
continue to use all of our authorities to prevent the use of third countries to illegally obtain
critical U.S. items.”
“We will not hesitate to identify and impose license requirements on entities that engage in acts
contrary to U.S. national security and foreign policy interests,” said Assistant Secretary of
Commerce for Export Administration Thea D. Rozman Kendler. “This includes sending
U.S. items to Russian military programs.”
The Bureau of Industry and Security protects against American dual-use items from being used
in ways contrary to U.S. national security and foreign policy objectives. Today’s rule applies
some of the Department’s most severe export restrictions on these entities, effectively cutting
them off from legally accessing items subject to U.S. jurisdiction.
The text of the rule released on November 17 and formally published on November 21 which
includes the list of entities, is available on the Federal Register’s website here. The
effective date for the rule is November 17, 2023.
Additional Background on the Entity List Process
These BIS actions were taken under the authority of the Export Control Reform Act of 2018 and
its implementing regulations, the Export Administration Regulations (EAR).
The Entity List (supplement no. 4 to part 744 of the EAR) identifies entities for which there is
reasonable cause to believe, based on specific and articulable facts, that the entities—including
businesses, research institutions, government and private organizations, individuals, and other
types of legal persons—that have been involved, are involved, or pose a significant risk of being
or becoming involved in activities contrary to the national security or foreign policy of the
United States. Parties on the Entity List are subject to individual licensing requirements and
policies supplemental to those found elsewhere in the EAR.
Entity List additions are determined by the interagency End-User Review Committee (ERC),
comprised of the Departments of Commerce (Chair), Defense, State, Energy, and where
appropriate, the Treasury, based on specific and articulable facts that the entities have been
involved, are involved, or pose a significant risk of being or becoming involved in activities
contrary to the national security or foreign policy interests of the United States.
The ERC makes decisions regarding additions to, removals from, or other modifications to the
Entity List. The ERC makes all decisions to add an entity to the Entity List by majority vote and
makes all decisions to remove or modify an entity by unanimous vote.
Additional information on the Entity List is available on BIS’s website here.