On December 19, the Bureau of Industry and Security (“BIS”) added 13 new entities to its Unverified List (“UVL”). All 13 of these entities were added under the destination of the Peoples’ Republic of China (“PRC”) on the basis that BIS was unable to verify their bona fides.

The UVL contains the names and addresses of foreign persons who have been parties to a transaction involving the export, reexport, or transfer of items subject to the EAR, but for whom U.S. officials have been unable to verify the legitimacy and reliability of the end-use and end user through an end-use check.

Listing on the UVL does not mean that U.S. exporters, re-exporters, and transferors cannot transact with listed parties. Rather, for transactions involving parties on the UVL, exporters are unable to invoke EAR license exceptions, and the transactions require additional documentation and recordkeeping processes, including obtaining UVL statements from officials of listed parties.

The list of entities added follows:

  • Beijing Jin Sheng Bo Yue Technology Co., Ltd., Haidian District, Zhi Chun Road, No. 118, Building A, Third Floor, Beijing, 30110, China
  • Beijing Shengbo Xietong Technology Co., Ltd., Building 8, Courtyard 6, Haiying Rd, Science City, Fengtai District, Beijing, 100160, China
  • Fulian Precision Electronics (Tianjin) Co., Ltd., No. 36, North Street, West Zone, Economic & Technological Development Area, Tianjin, 300462, China
  • Guangzhou Xinwei Transportation Co., Ltd., Unit 214 Building A1, 9 Konggang Avenue Jiuyi Village, Huadu Town, Huadu District, Guangzhou, Guangdong, 519997, China
  • Guangzhou Xinyun Intelligent Technology Co., Ltd., No. 30, Liangtian Baoshui Rd, Liangtian Village, Zhongluotan, Guangzhou, 519997, China
  • Nanning Fulian Fu Gui Precision Industrial Co., Ltd., B Factories Area, Foxconn Nanning Science and Technology Park, No. 51, Tongle Avenue, Nanning, Guangxi 518000, China
  • Ningbo MOOF Trading Co., Ltd., Room 312, Bldg 3, Chengxi Xintiandi, No. 799 Jucai Rd, Haishu District, Ningbo, China
  • Plexus (Xiamen) Co., Ltd., No. 6 Xian Xing 2 Road, Xiang Yu Free Trade Zone, Xiamen, Fujian, China
  • PNC Systems (Jiangsu) Co., Ltd., No 500 Linyang Road, Qidong Economic Development Zone, Qidong, 226299, China
  • Shenzhen Bozhitongda Technologic Co., Ltd., Rm 802, Shanhuju, Shenzhen, Luohu, 518000, China; and No. 3018 Shennan Avenue, Huahang Community, Huaqiangbei Street, Futian District, Shenzhen City, China; and No. 3407, Century Plaza, Zhonghang Road, Huaqiangbei Street, Futian District, Shenzhen City, China
  • Shenzhen Jia Li Chuang Tech Development Co., Ltd., 27/F, Aolinpike 2 Building, Shangbao Rd, Futian District, Shenzhen, Guangdong, 518034, China
  • Shenzhen Jingelang Co., Ltd., Rm 401, Plant 18, New 1#, Jinpeng Industrial Park, Xinxue Community, Bantian Str., Longgang District, Shenzhen, Guangdong, 519997, China
  • Xi’An Yierda Co., Ltd., Lian Hu Qu, Feng He Lu #251, Xin Yuan Center 1316, Xi’An, Sha’an Xi, 710014, China
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Photo of Jana del-Cerro Jana del-Cerro

Maria Alejandra (Jana) del-Cerro is a partner in Crowell & Moring’s Washington, D.C. office and a member of the firm’s International Trade and Government Contracts groups. She advises clients with respect to the U.S. regulation of outbound trade, including U.S. export controls. Jana

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Maria Alejandra (Jana) del-Cerro is a partner in Crowell & Moring’s Washington, D.C. office and a member of the firm’s International Trade and Government Contracts groups. She advises clients with respect to the U.S. regulation of outbound trade, including U.S. export controls. Jana works with clients across a broad range of industries, from traditional aerospace and defense manufacturers and multi-national software companies, to start-ups in the technology sector, and she regularly represents them before the Departments of State, Commerce, and Treasury in responding to government inquiries, conducting internal reviews, and in compliance investigations and voluntary disclosures.

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Photo of Andrew J. Schlegel Andrew J. Schlegel

Andrew Schlegel is an international trade analyst III in Crowell & Moring’s Washington, D.C. office. He provides practice support to the International Trade Group on import regulatory matters pending before the Office of the U.S. Trade Representative (USTR) and U.S. Customs and Border

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Andrew Schlegel is an international trade analyst III in Crowell & Moring’s Washington, D.C. office. He provides practice support to the International Trade Group on import regulatory matters pending before the Office of the U.S. Trade Representative (USTR) and U.S. Customs and Border Protection (CBP). He works closely with attorneys developing courses of action for clients impacted by investigations under Section 301 of the Trade Act of 1974 and Section 232 of the Trade Expansion Act of 1962. Andrew also supports unfair trade investigations, including antidumping (AD) and countervailing duty (CVD) investigations, sunset reviews, and changed circumstance reviews before the Department of Commerce and the International Trade Commission (ITC).

Prior to joining Crowell & Moring, Andrew worked as an intern at SAP’s Government Affairs Business Development Team in Berlin, Germany. There, he analyzed the effects of regulatory changes on SAP business operations and expansion opportunities. Before this, he completed an internship at the International Trade Administration’s Office of Energy and Environmental Industries. While there, he developed the U.S. Energy Trade Dashboard, an interactive data visualization tool for use by professionals and researchers to analyze how energy supply chains have developed.

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