Are all of the persons on the Entity List included because they violated the Export Administration Regulations (EAR) by exporting, reexporting and/or transferring items subject to the EAR?
No, not all sections of Part 744 of the EAR (which defines the criteria for consideration for inclusion on the Entity List) require that a persons alleged activity involve items subject to the EAR. Section 744.11, for example, requires that the persons activities are contrary to U.S. national security and/or foreign policy interests but does not require that the activities involve the diversion of items subject to the EAR.
No, not all sections of Part 744 of the EAR (which defines the criteria for possible inclusion on the Entity List) require that a person’s alleged activity involve items subject to the EAR. Section 744.11, for example, requires that the person’s activities be contrary to U.S. national security and/or foreign policy interests but does not require that the activities involve items subject to the EAR.