On September 12, 2025, the Bureau of Industry and Security (BIS) published a final rule announcing additions to the Entity List. 32 new entities across China, India, Iran, Singapore, Taiwan, Turkey, and the United Arab Emirates (UAE) have been added to the Entity List due to activities deemed contrary to U.S. national security or foreign policy interests.

Notable additions include multiple semiconductor and technology companies in China—such as Shanghai Fudan Microelectronics and its affiliates in China, Singapore, and Taiwan—due to their roles in supporting military modernization and circumventing export controls. Several Turkish firms, including Atempo Proje Taahhüt and EB Teknoloji Sistemleri, were listed for diverting U.S.-origin items to Russia. In the UAE, HAS General Trading LLC and Smart Mail Services have been added for facilitating unauthorized transshipments to Iran and Russia. Additional entities in India and Iran, such as AR Sales Pvt Ltd and Smart Mail Services, are cited for similar diversion activities.

All listed entities are now subject to a license requirement for all items subject to the Export Administration Regulations (EAR), with a presumption of denial for license applications.

Contact the Husch Blackwell International Trade Team for assistance in reviewing your current and prospective business relationships and transactions to ensure compliance with these new restrictions.