Overhaul of the BIS Unverified List

Effective January 21, 2014, a new rule issued by BIS have significant impact to traders.  It is overhaul of BIS Unverified List ("UVL") screening requirement.  The bullet points of changes are as follows.

• UVL is reshuffled.  All parties listed on the current UVL will be removed, and subsequently be added to a new UVL.  (as of today, I don't find new UVL on the BIS web site, though.)
• Exporters will need to file an AES records (customs declaration in US) for all exports to the entities on UVL.  This is nearly no exception.
• No license exceptions will apply for exports, re-exports, and transfers (in-country) of items subject to the EAR to the transaction with UVL entities.
• For no license required transaction under the EAR, exporters must obtain a signed and dated written statement from UVL entities before the transactions.

See news letter from Bryan Cave LLP in;
http://www.bryancave.com/files/Publication/a061fbc1-d778-4c73-bd82-553bfab0316c/Presentation/PublicationAttachment/45281c4e-2dc0-471d-bf0c-57c8a8145d69/IRB516.pdf