On August 30, BIS published due diligence guidance regarding exports, reexports, and transfers (in-country) to Pakistan, providing information on supplemental licensing requirements related to items potentially destined for nuclear or missile end-users or end-uses. BIS highlighted best practices for screening customers in Pakistan in order to decrease the risk of diversion to unauthorized end uses and end users. This guidance comes as a result of BIS recently adding certain companies from Pakistan to their Entity List, as well as investigations by the Office of Export Enforcement that uncovered schemes to ship items subject to the EAR to Pakistani end-users on the Entity List without meeting the proper licensing requirements. The guidance also identifies a number of EAR99 items and items controlled for Antiterrorism reasons only that have been sought by nuclear- or missile (including UAV)-related entities, including certain connectors, electromechanical relays, gas measurement equipment, and power supplies.
For more information on how this could impact your business, contact:
- Martin Lutz, Partner (firstname.lastname@example.org, 512-495-6024)
- Lindsey Roskopf, Attorney (email@example.com, 713-615-8534)
- or another member of the McGinnis Lochridge International Trade and Transactions Practice Group