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BIS Adds Four ZTE Entities to the Entity List

By Ed Krauland & Alexandra Baj on March 9, 2016
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On March 8, 2016, the US Department of Commerce Bureau of Industry and Security (BIS) published a Federal Register notice adding four ZTE entities to the BIS Entity list.  Three of the entities are located in China and one is located in Iran.  The Chinese entities are:  (1) Beijing 8-Star International Co., (2) Zhongxing Telecommunications Equipment (ZTE) Corporation; and (3) ZTE Kangxun Telecommunications Ltd.  The Iranian entity is ZTE Parsian.

The Entity List designation for these entities states that any “item that is subject to the Export Administration Regulations” will require a BIS license for export, re-export, or in-country transfer to any of the four entities.  A license requirement also exists for any transaction in which one of the four named entities “act as purchaser, intermediate consignee, ultimate consignee, or end user of items subject to the EAR”.  In addition, the licensing policy for such applications will be a presumption of denial, meaning that licenses will not be approved without a compelling reason for the US government to overcome the presumption.  Similarly, license exceptions are not available for exports, reexports or in-country transfers of items subject to the Export Administration Regulations to the four entities.

“Items subject to the Export Administration Regulations” include the following:

  1. All US origin items wherever located in the world.
  2. Any item in the United States and being exported to any of these entities from the United States.
  3. Any foreign made item that contains more than 25% US origin “controlled” content (or 10% if exported or reexported to Iran, North Korea, Sudan, or Syria) (the so-called “de minimis” rule).
  4. Any foreign made item that is the direct product of US origin technology or major plant and equipment located abroad, where the foreign-made product and the US origin technology or major plant and equipment are controlled for “national security” reasons.
Photo of Ed Krauland Ed Krauland

Edward J. Krauland focuses on export controls/economic sanctions. Ed’s extensive experience includes representing clients on matters involving US and multilateral economic sanctions, defense and nuclear export controls, dual-use export controls under the EAR, anti-boycott compliance, internal investigations and enforcement work, and review of…

Edward J. Krauland focuses on export controls/economic sanctions. Ed’s extensive experience includes representing clients on matters involving US and multilateral economic sanctions, defense and nuclear export controls, dual-use export controls under the EAR, anti-boycott compliance, internal investigations and enforcement work, and review of government procurement regulations in the cross-border context. His practice spans all aspects of these laws, including counseling, compliance work, transactional advice, licensing and opinion work, internal reviews, disclosures, and enforcement actions. He has served as co-chair of the International Trade Committee of the ABA Section of International Law and Practice. He is former Chairman of an ABA-wide Task Force on Gatekeeper Regulation (anti-money laundering compliance), and senior adviser to the ABA Section of International Law and Practice’s anti-money laundering committee.

Read Ed’s full bio.

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Photo of Alexandra Baj Alexandra Baj

Alex Baj’s practice primarily involves export controls and economic sanctions laws and regulations, anti-corruption investigations and compliance, international trade, and security clearance issues. Alex advises clients on export control and economic sanctions laws and regulations, including the Export Administration Regulations (EAR), International…

Alex Baj’s practice primarily involves export controls and economic sanctions laws and regulations, anti-corruption investigations and compliance, international trade, and security clearance issues. Alex advises clients on export control and economic sanctions laws and regulations, including the Export Administration Regulations (EAR), International Traffic in Arms Regulations (ITAR), US sanctions regulations administered by the Office of Foreign Assets Control (OFAC), and nuclear export controls under the jurisdiction of the Nuclear Regulatory Commission (NRC).  Alex specializes in the development and implementation of export and anti-corruption compliance policies and procedures and training, internal investigations and voluntary disclosures under the EAR, the ITAR, and OFAC rules, due diligence for mergers and acquisitions, and on encryption and cybersecurity export controls.  Her clients include companies involved in defense, aerospace, software, semiconductor, and uranium processing industries.

Read Alex’s full bio.

Read more about Alexandra BajEmail
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  • Posted in:
    Government Contracts
  • Blog:
    International Compliance Blog
  • Organization:
    Steptoe LLP

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