LETT TRONIC GROUP LIMITED (LETT TRONIC) is a Hong Kong-based company that sent more than 300 shipments worth nearly $2 million of CHPL items such as microelectronic components to ELESAR GRUPP, including U.S.-origin integrated circuits, between June 2023 and January 2024. LETT TRONIC sent shipments of CHPL items to several U.S.- designated, Russia-based companies including ROSTAR RESEARCH AND PRODUCTION ASSOCIATION LIMITED LIABILITY COMPANY, MAKRO TIM LIMITED LIABILITY COMPANY, NAUCHNO PROIZVODSTVENNOE PREDPRIYATIE ITELMA, and BEE PITRON LIMITED. LETT TRONIC has sent shipments of CHPL items to Russia on behalf of U.S.-designated, Türkiye-based ASAY IC VE DIS TICARET LIMITED SIRKETI.
Entity List (EL) - Bureau of Industry and Security
Regime
BIS Export Control
Target State
Non-Proliferation
Measures
Other export restrictions
Official Information
The BIS Entity List has evolved into a formidable administrative enforcement tool that imposes a license requirement for exports, reexports, or transfers of some or all items subject to the EAR to listed foreign entities. Those on the BIS Entity List were placed there because there is reasonable cause to believe they have been involved, are involved, or pose a significant risk of being or becoming involved in activities contrary to U.S. national security or foreign policy, such as WMD programs, destabilizing accumulations of conventional weapons, terrorism, or enabling human rights abuses.
These license requirements are in addition to any license requirements imposed on the transaction by other provisions of the EAR. As a general rule, BIS generally applies a presumption of denial for license applications involving listed entities. The Entity List thereby serves as an incentive for listed foreign parties to implement effective export management compliance programs to stop the diversion of U.S.-origin items to unauthorized destinations, uses, or users, thereby providing a basis for removal. General Orders also may restrict exports to named individuals or entities. For General Orders, see Supplement No. 1 of Part 736 of the EAR.
For guidance concerning the license application review policy applicable to a particular entity, please review that individual or organization’s entry on the list. Listed entities may request removal from the Entity List by submitting a petition pursuant to Section 744.16 and Supplement 5 to Part 744 of the EAR.
Program URL
• BIS, "Don’t Let This Happen to You!", a compendium of case examples highlighting BIS criminal and administrative enforcement efforts: link
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