In efforts to prevent transshipment of U.S. high-technology goods to unstable regions in the world, the U.S. Department of Commerce (DOC) has indicated that it will create a new country group under its export control regulations. “Country Group C,” as it has been dubbed, will include countries known to be illegally re-exporting high-technology products to Iran, Syria and other countries of concern. “Country Group C” could also be subject to a more rigorous export licensing process that could result in fewer approvals. While the countries to be included in this new country group have yet to be identified, according to DOC officials, the United Arab Emirates (UAE) would be high on the list of countries targeted by the new controls.

Related to exports to the UAE, the Bureau of Industry and Security (BIS) issued a final rule that amends the Export Administration Regulations to add two UAE entities to the Entity List. Two entities have been added to the Entity List in 15 C.F.R. Part 744, Supplement No. 4: (1) Bazaar Trading Co., No. 212 Baniyas Tower, Dubai, UAE 6708, and (2) Elmstone Trading L.L.C., P.O. Box 24896, Sharjah, UAE. According to BIS, these entities present an unacceptable diversion risk and therefore exports to these entities will require licenses.