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BIS Seeks to Strengthen the Unverified List

18 September 2013

Export Controls Alert

On 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, re-exports, 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.

Read More: BIS Seeks to Strengthen the Unverified List

The team

H.P. Goldfield

H.P. Goldfield

Senior International Affairs Advisor
Washington, D.C.

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