The U.S. government maintains many lists of persons and entities that the U.S. government prohibits U.S. companies to export, reexport, or transfer (in-country) items subject to the Export Administration Regulations. One such lists is the Unverified list (UVL). The list includes names and addresses of persons not eligible to receive items subject to the EAR with a license exception. The persons (individuals and entities) are included in the list because the Bureau of Industry and Security (BIS) cannot verify their bona fides (e. the legitimacy and reliability related to end – use and end – user of items subject to the EAR). For a company to export, re-export, or transfer (in-country) items subject to the EAR, to a party on the UVL list, a company must 1. Obtain a statement, the UVL statement, from the other party before exporting, re-exporting, or (in-country) transfer; 2. Make an EEI filing on the Automated Export System for all tangible exports to parties on the UVL; 3. maintain records of the UVL statement.
A party may be removed from the UVL list, following procedures set out in the EAR, provided that they demonstrate their bona fides. Important to note is that BIS updates this list frequently so as a company it is incumbent upon you or your counsel to keep a close eye on any updates that happen to the UVL. The most recent update was on October 13, 2022, where BIS added 31 persons mainly from China on the UVL list and removed nine persons.
If you have questions about the UVL or issues related to the control of dual use items mail to: firstname.lastname@example.org or text a secure message at 734.746.5006 (do not include confidential information)