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Do the license requirements and policies of the Entity List apply to branch office and subsidiaries if the parent company is the listed entity?

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Do the license requirements and policies of the Entity List apply to branch office and subsidiaries if the parent company is the listed entity?

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If the branch office is part of the listed entity (i.e., is not a distinct company itself), the Entity List’s licensing requirements and policies are as applicable to the branch location as to its company headquarters. BIS considers branches and field offices that are not legally distinct from the company that is the listed entity to be integral parts of that company. By contrast, separately incorporated subsidiaries or sister companies are not considered part of the listed entity and are therefore usually not covered by the Entity List’s prohibitions. BIS recommends an extra level of due diligence in these cases to ensure that the subsidiary or sister company is not engaging in the activities that resulted in the listed entity’s inclusion on the Entity List, is not engaging in transactions on behalf of the entity on the Entity List, and is a bona fide organization that is separate and distinct from its parent or sister company (i.e. is not merely a front or shell company for the liste

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