On September 12, 2025, the U.S. Department of Commerce's Bureau of Industry and Security (BIS) released a final rule that announced the addition of 32 new entities to the Entity List (see BIS final rule here). 23 entities were added under the destination of China, one under India, one under Iran, one under Singapore, one under Taiwan, three under Turkey, and two under the UAE. The newly added entities include Chinese chipmakers and biotechnology companies, Turkish firms that diverted U.S. origin goods on the Common High Priority List (CHPL) to Russia, and an UAE trading company that diverted non-EAR99 items to Iran and Russia.
All exports to these entities of items subject to the EAR now require a license, and BIS will review these license applications under either a presumption or policy of denial.
The reasons that BIS cited for the addition of the new entities include:
- Their contribution to China's quantum technology capabilities and military modernization efforts;
- Acquisition of U.S. origin-items for diversion to parties on the Entity List (specifically, for diversion to major Chinese chipmaker SMIC);
- Export of U.S.-origin CHPL electronics to Russia and contribution to procurement networks for Russia's defense industry and intelligence services;
- Supplying of technology to Russian military end users;
- Diversion of U.S. origin items to Russia without prior authorization from BIS;
- Facilitation of transshipment to Russia and Iran;
- Export or attempted export of items on the Commerce Control List (CCL) from the U.S. to Russia and Iran;
- Diversion of dual-use items in support of the Iranian military;
- Evasion of BIS end-use checks (EUCs).
It is notable that BIS added certain entities solely for their efforts to export CHPL items to Russia because: (i) it is the first instance of the Trump Administration designating entities on the Entity List for Russia-related activity; and (ii) the citation to the CHPL is a reference that the Trump Administration is still relying on mechanisms created during the Biden Administration that other G7 countries are relying upon as well.
The final rule also revises an entry by removing two addresses from one entity under the destination of Russia, and modifies 27 existing entities on the Entity List to correct for typographical errors.
The final rule is effective September 12, 2025.
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