The Bureau of Industry and Security Adds Eight Entities to the Entity List for Violating Human Rights

On December 10, 2024, the U.S. Bureau of Industry & Security (BIS) of the Commerce Department issued a final notice and added 8 entities to the Entity List of the Export Administration Regulations (EAR). This rule targets entities involved in abusing human rights or acting contrary to the foreign policy & national security interest of the U.S., specifically in China, Burma, and Russia.

Human rights abuses are contrary to the foreign policy interests of the United States. By adding these parties to the Entity List with the presumption of denial license review policy, we aim to ensure that U.S. technology is not used to enable human rights violations and abuses.”

Alan F. Estevez, Under Secretary of Commerce for Industry and Security

BIS will also impose licensing requirements for U.S. suppliers that are involved in re-exporting, exporting, and transfer of any commodity to listed entities.

The following PRC entities were added:

Burma

• Sky Aviator Company Limited
• Synpex Shwe Company Ltd.

These companies supplied the Burmese military with components & parts that have enabled the military to carry out human rights violations such as brutal aerial attacks against the civilian population.

China

• Beijing Zhongdun Security Technology Group Co., Ltd.
• Zhejiang Uniview Technologies Co., Ltd.

Beijing Zhongdun Security Technology Group Co., Ltd. sells & develops products and services that enable China’s public security establishment to violate human rights.

Zhejiang Uniview Technologies Co., Ltd. was involved in human rights violations such as high-technology surveillance targeting the general population of Uyghurs, China & different members of other religions and ethnic minority groups.

Russia

• NTechLab LLC
• Technology Videoanalysis LLC
• Aviasnab LLC
• Joint Stock Company Gorizont

Technology Videoanalysis LLC & NTechLab LLC develop & supply facial recognition software to the Russian government that tracks and targets peaceful activists & protestors.

“BIS is deeply committed to protecting human rights and vulnerable populations throughout the world. Today’s action will prevent bad actors from misusing items subject to our controls for malign purposes.”

Thea D. Rozman Kendler, Assistant Secretary of Commerce for Export Administration

The End-User Review Committee (ERC), which includes the Departments of Commerce, Energy, State, Defense, and Treasury (if necessary), will decide how the entity will be modified, removed, or added to the entity list.

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According to a press release, ERC will decide to add an entity to the entity list by majority vote & to modify or remove an entity by unanimous vote.

Export Administration Regulation (EAR) & Export Control Reform Act of 2018 were responsible for these BIS actions. Parties mentioned in the Entity List are also subjected to supplemental policies and individual licensing requirements for those found elsewhere in the EAR.