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Focus on Regulation

BIS seeks to strengthen the Unverified List

globeOn 11 September 2013 the Department of Commerce’s Bureau of Industry and Security (BIS) proposed significant revisions to the Unverified List (UVL) provisions in the Export Administration Regulations (EAR). See Revisions to the Export Administration Regulations (EAR): Unverified List (UVL), 78 Fed. Reg. 55664 (Sep. 11, 2013). BIS proposes to amend the EAR by: (1) requiring exporters to file an Automated Export System (AES) record for all exports subject to the EAR involving entities listed on the UVL even if the transaction is otherwise eligible for an exemption from reporting; (2) suspending the availability of license exceptions for exports, reexports, and transfers (in-country) involving entities listed on the UVL; (3) requiring exporters, reexporters, and transferors (in-country) to obtain an end-user statement from UVL-listed entities before proceeding with exports, reexports, and transfers (in-country); and (4) adding to the EAR procedures to request removal or modification of a UVL entry.

BIS has proposed these changes in order to increase its own awareness of transactions involving UVL entities, and to encourage exporters to apply more scrutiny to transactions involving UVL-listed entities. Companies doing business with UVL entities should review their current compliance procedures.

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