The U.S. Bureau of Industry and Security (BIS) placed 26 entities and three Hong Kong addresses under sharp export controls on Wednesday for facilitating Iran and its networks, in BIS’s first expansion of the Entity List since the rollout of the 50% “Affiliates” rule.
This latest group of additions, BIS’s second in less than a month, targeted Chinese and Turkish companies that had diverted U.S.-origin electronic components for military end use by Iran and its facilitators. Some of the components in question, BIS said, had been found in weaponized drones recovered by the Israeli Defense Force after the Oct. 7, 2023, attacks by Hamas, an Iranian proxy group.
The new listings, which landed the day after those attacks’ two-year anniversary, add to an intensifying Western focus on Iran in recent weeks—following the United Nations’ “snapback” to pre-2015 sanctions, ensuing EU and U.K. restrictions, and fresh U.S. designations.
But the new BIS 50% rule gave Wednesday’s measures a distinct backdrop.
BIS also emphasized its new red flag of unknown ownership by listed parties.
About the addresses: Meanwhile, the addition of the Hong Kong addresses underscores how address-based links can signal high diversion risks and why address screening has become critical to sanctions and trade compliance. Recent U.S. government guidance has emphasized the need for exporters and financial institutions to screen not only entities and individuals but also locations that may serve as fronts or transshipment points.
According to corporate records reviewed by Kharon, one of the newly listed addresses was until February 2025 the registered address of HK Jinzhong Business Group Limited. That company has acted as a corporate secretary to at least two entities, Micro Device Co., Limited and Athena Shipping Co., Limited, that the Treasury Department has sanctioned this year for their involvement in Iran’s military procurement.
Micro Device connects this broader web by another means as well: The company’s current owner, Treasury said in designating it last week, is Emily Liu’s brother-in-law.
More on the Entity List and 50% rule:
This latest group of additions, BIS’s second in less than a month, targeted Chinese and Turkish companies that had diverted U.S.-origin electronic components for military end use by Iran and its facilitators. Some of the components in question, BIS said, had been found in weaponized drones recovered by the Israeli Defense Force after the Oct. 7, 2023, attacks by Hamas, an Iranian proxy group.
The new listings, which landed the day after those attacks’ two-year anniversary, add to an intensifying Western focus on Iran in recent weeks—following the United Nations’ “snapback” to pre-2015 sanctions, ensuing EU and U.K. restrictions, and fresh U.S. designations.
But the new BIS 50% rule gave Wednesday’s measures a distinct backdrop.
The 50% rule guidance
For the first time, the Federal Register notice for the additions included a warning about the requirements for U.S. exporters under its interim Affiliates rule. Now, BIS noted, Entity List licensing requirements and other restrictions “also apply to any foreign entity that is owned, directly or indirectly, individually or in aggregate, 50 percent or more by one or more listed entities.”BIS also emphasized its new red flag of unknown ownership by listed parties.
- “If an exporter, reexporter, or transferor cannot determine the ownership percentage of a foreign entity that is an entity owned by one or more listed entities, they must resolve the Red Flag or obtain a license from BIS prior to proceeding with the export, reexport, or transfer (in-country), unless a license exception is available,” the Federal Register notice said.
The additions
1. Sixteen Chinese and Hong Kong-based entities, for facilitating Iran-tied unmanned aircraft procurement networks.- Ten, BIS said, had facilitated the purchase of U.S.-origin electronic components recovered in “numerous weaponized unmanned aircraft systems” operated by Iranian proxies, including Houthi militants in Yemen.
- Five had facilitated the purchase and procurement of U.S.-origin electronic components that Israel identified in Hamas-operated drones.
- And one last Chinese entity, Goodview Global, was singled out for being “part of an illicit procurement network that supplies components, including UAV components, to front companies of the Islamic Revolutionary Guard Corps’ Qods Force.”
- BIS listed an additional Turkish entity, along with one UAE entity, for diverting U.S.-origin items to Iran, including some related to chemical manufacturing.
- One final Turkish entity, TGB Aviation, was added for having been “associated with the transshipment of U.S.-origin aircraft components into Iran,” in a network connected to U.S.-sanctioned Iran Aircraft Manufacturing Industries.
- The U.S. had most recently charged Liu and three other Chinese nationals in January 2024 for running “a years-long conspiracy to unlawfully export and smuggle U.S.-origin electronic components from the United States to Iran.”
- The use of the Entity List to undercut Iranian diversion appears to be new. Previous listings of addresses were aimed at Russian evasion networks—though those were in Hong Kong as well.
What Kharon’s research found
About the entities: Several of the new firms on the Entity List have majority subsidiaries that were not named but would presumably fall under the restrictions of the 50% rule.- Easy Fly Intelligent (Hubei) Drone Technology Co., Ltd, a drone technology services company, is owned 100% by the newly listed Easy Fly Intelligent Technology Co., Ltd.
- Xi'an Kevins Data App Co., Ltd., which specializes in radio-frequency identification data and “data application” hardware solutions, is wholly owned by the newly listed Beijing Kevins Technology Development Co., Ltd.
About the addresses: Meanwhile, the addition of the Hong Kong addresses underscores how address-based links can signal high diversion risks and why address screening has become critical to sanctions and trade compliance. Recent U.S. government guidance has emphasized the need for exporters and financial institutions to screen not only entities and individuals but also locations that may serve as fronts or transshipment points.
According to corporate records reviewed by Kharon, one of the newly listed addresses was until February 2025 the registered address of HK Jinzhong Business Group Limited. That company has acted as a corporate secretary to at least two entities, Micro Device Co., Limited and Athena Shipping Co., Limited, that the Treasury Department has sanctioned this year for their involvement in Iran’s military procurement.
Micro Device connects this broader web by another means as well: The company’s current owner, Treasury said in designating it last week, is Emily Liu’s brother-in-law.
More on the Entity List and 50% rule:
