The U.S. Department of Commerce’s Bureau of Industry and Security (BIS) published a Final Rule on October 9, 2025 that will add 26 entities and three addresses to the Entity List for a total of 29 new entries (effective immediately).  BIS’ Entity Review Committee (ERC)—composed mainly of the Departments of Commerce, State, Defense, Energy, and Treasury—targeted these entities for their alleged role in illegally supplying Iran with unmanned aircraft systems (UAS) parts and components, electronic and chemical manufacturing items (including of U.S.-origin), as well as links to an illicit procurement network. 

The entities and addresses are located in the People’s Republic of China (19), Turkey (9), and the United Arab Emirates (1).  All exports, reexports, and transfers (in country) of items (subject to the U.S. Export Administration Regulations) to these entities, as well as their “affiliates” caught under the new BIS Affiliates Rule, will now require BIS authorization, even if the exporter is a non-U.S. person.  License applications will be reviewed under a “presumption of denial” policy.

BIS highlighted that since 2017, countries in the Middle East have found “weaponized” UAS—including aircraft containing U.S.-origin electronic components—operated by Iranian proxies, such as Houthi and Hamas militants.

Of the 19 Chinese entries added, the BIS determined the following:

• One (1) entity was part of an illicit procurement network that supplies UAS components to Iran.
• Ten (10) facilitated Iran’s purchase of electronic components (including U.S.-origin items) used in UAS.
• Five (5) helped Iranian proxies (including Hamas) buy and procure electronic components found in Iranian-made weaponized drones recovered by Israel Defense Forces following the October 7, 2023, attack on Israel.
• Three (3) addresses were associated with providing or attempting to provide a sanctioned Iranian entity tied with Iran’s Ministry of Defense.

In addition to the China destinations, BIS noted seven (7) Turkish entities diverted U.S.-origin items to Iran; one Turkish entity was involved in transshipment of U.S.-origin aircraft components into Iran; while another Turkish company, along with a UAE one, diverted U.S.-origin chemical manufacturing equipment to Iran. 

This means there are now a total of 19 address-only entries: 18 in China and one in Turkey, unassociated with a specific entity. BIS has guidance in its Entity List FAQs for conducting diligence on address-only entries.

Combined with the recent “Affiliates Rule,” this new rule is a significant development as it expands the number of entities subject to BIS restrictions, targeting not just these 26 entities but potentially many more involved in aiding Iran and its proxies in securing U.S.-origin electronic components for Iranian drones and other weapon systems.  These drones have been playing an increasingly pivotal role in Russia’s war against Ukraine as well as in conflicts across the Middle East.