On October 8, 2025 (local time), the Bureau of Industry and Security (BIS) under the U.S. Department of Commerce released a notice. According to this notice, 26 entities and 3 addresses were added to the Entity List. Among them, there are 16 companies from mainland China and 3 addresses located in Hong Kong, China. The BIS clarified that this action is specifically aimed at disrupting intermediary networks. These networks have been procuring electronic components of U.S. origin for Iran and its affiliated organizations. A substantial number of the entities involved are distribution, technology, and logistics firms operating in mainland China and Hong Kong. Among the listed companies, there are the Chinese and Hong Kong subsidiaries of Arrow, a well - known global electronic component distributor. Additionally, numerous small - to - medium - sized technology and trading firms are also on the list. In terms of licensing requirements, for all the listed entities and addresses, the regulations "applicable to all items subject to the EAR" will be enforced. The licensing review policy is set as a "presumption of denial," which means that there is a general assumption that license applications will be denied. Moreover, most license exceptions will no longer be available for these listed entities and addresses.
