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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?

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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?

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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.

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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.

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