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6. Are U.S. companies prohibited under the EAR from doing business with specific entities that are not included on the Entity List? [1]
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Date: 2022-07
Yes. However, BIS considers that transactions of any nature with listed entities carry a "red flag" and recommends that U.S. companies proceed with caution with respect to such transactions. Note that the Entity List describes license requirements and policies for the export, reexport, and/or transfer (in-country) of items subject to the EAR only. Additionally, although many of the persons included on the Entity List are subject to policies of denial for the export, reexport, and/or transfer (in-country) of all items subject to the EAR, some are subject to policies and requirements that are narrower in scope (i.e., not all persons included on the Entity List are subject to license requirements for all items subject to the EAR, while others are subject to license requirements for all or some items listed on the Commerce Control List (CCL)). Be sure to review the licensing policy and requirements carefully.
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[1] Url:
https://www.bis.doc.gov/index.php/cbc-faqs/faq/286-are-u-s-companies-prohibited-under-the-ear-from-doing-business-with-specific-entities-that-are-not-included-on-the-entity-list-2#faq_285
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