The U.S. Department of Commerce's Bureau of Industry and Security (BIS) is extending until August 30, 2016, the general license for exports, reexports (shipments from one foreign country to another foreign country), and in-country transfers of items subject to the Export Administration Regulations (EAR) to Zhongxing Telecommunications Equipment Corporation (ZTE) and its affiliate, ZTE Kangxun Telecommunications Ltd. (ZTE Kangxun). On March 8, these entities were added to BIS's Entity List and, as a result, a license requirement was imposed on the export, reexport, and in-country transfer of any item subject to the EAR to ZTE and ZTE Kangxun. (See our WSGR Alert published on March 7.) On March 23, 2016, BIS issued a general license "suspending" the license requirement imposed by the Entity List. As a result, the license requirement status returned to the same level that existed prior to ZTE's and ZTE Kangxun's inclusion on the Entity List. Thus, if an export to ZTE did not require a license prior to the March 8 listing, then that export would continue to not require a license as a result of the general license. Further, license exceptions may continue to be used for exports, reexports, and in-country shipments to ZTE and ZTE Kangxun.

The general license is in effect until August 30, 2016, and may be renewed again by BIS. Restrictions on the export, reexport, and transfer to the two additional entities added to the Entity List with ZTE, ZTE Parsian, and Beijing 8-Star remain in effect.

If you would like to discuss this matter, please contact Josephine Aiello LeBeau, 202-973-8813, jalebeau@wsgr.com; Anne Seymour, 202-973-8874, aseymour@wsgr.com; or any member of the export control and economic sanctions regulatory practice at Wilson Sonsini.