The latest list of BIS sanctions for the United States in 2022 has been released, including a new content - unverified lists containing the names and addresses of foreign entities that belong or have belonged to one party to the transaction, involving the export, re export, or transfer of EAR bound items (domestically), whose authenticity (i.e. legality and reliability related to the end use and end-users of EAR bound items) cannot be verified by BIS through end use checks. Our domestic substitution has reached an urgent point, and the US sanctions have gradually become comprehensive sanctions on raw materials and new technologies. When the Bank for International Settlements or federal officials acting on behalf of the Bank for International Settlements are unable to satisfactorily complete the final use inspection (such as pre permit inspection (PLC) or post shipment verification (PSV)) due to reasons beyond the control of the US government and are unable to verify the authenticity of foreign entities, the Bank for International Settlements may add a list to the UVL.

1 AECC South Industry Co., Ltd. Dongjiaduan, Lusong District, Zhuzhou, Hunan Province, China

2 Beijing SWT Science Yingbinbei Road 36 Yanjiao Economic & Development Zone Sanhe City, Hebei Province, China

3 Beijing Zhonghehangxun Technology Co., Ltd. Room 1705, Kaixuancheng Building E No. 170 Beiyuan Road, Chaoyang District, Beijing, China

4 China National Erzhong Group Deyang Wanhang Die Forging Co., Ltd. No. 460 Zhujiang Road West, Deyang City, Sichuan Province, China

5 Chuzhou HKC Optoelectronics Technology Co., Ltd. No.101 Suchu Ave., Economic and Technological Development Zone, Nanqiao District, Chuzhou, Anhui Province 239000 China

The items on the US sanctions list are unverified, and although it is different from the "entity list", the restrictions on the UVL list are not as strict. The UVL list in the United States is mainly aimed at parties whose final use of goods cannot be confirmed by BIS in their previous transactions. But the sanctions imposed by the United States on China are becoming increasingly severe!

According to EAR § 740.2 (a) (17), no license exceptions shall be granted for the export, re export, or transfer of US origin items to purchasers, intermediate consignees, final consignees, or end-users listed on the UVL list. Unless the list on the UVL has been suspended, or in accordance with Article 744.15 (b) of the EAR, exporters, re exporters, and transferors must obtain (and maintain) a UVL declaration from one or more parties listed on the UVL before exporting, re exporting, and transferring (domestically) to entities on the UVL list, re exporting and transferring (domestically) may not be subject to license requirements.

In addition, entities listed on the UVL list may request the removal of UVL entries in accordance with Article 744.15 (d) of the EAR. The decision to cancel or modify the entry of UVL will be made by the Deputy Assistant Minister in charge of export enforcement based on the certification of its authenticity by the listed personnel.