Project 2025 Tracker / What’s done, what’s next

21. Department of Commerce · Notable

Deny export licenses to countries that block end-use checks

Partially done

672 21. Department of Commerce

“BIS must deny export licenses to countries that do not permit adequate end-use checks (e.g., China/Russia) by U.S. authorities.”

What has happened

  1. Partially done

    BIS added eighteen parties to the Unverified List — five of them in China — precisely because end-use checks on them could not be completed, and removed five others whose checks had since been completed. The Unverified List is the mechanism BIS uses against parties in countries that block end-use checks: it strips license exceptions and imposes a certification requirement, which is a piece of what the Quote asks for. What was not done is the country-level step: no policy denies export licenses to China or Russia on the ground that they bar end-use checks, and in January 2026 BIS moved the other way for advanced-computing items to China and Macau, changing the license review policy from a presumption of denial to case-by-case review.

Research log

What was searched, and what didn’t count as evidence

Research notes

§3 “part of the ask achieved”. BIS used the instrument that exists for this problem — the Unverified List — and used it against Chinese parties, but the Quote asks for outright denial of export licenses to countries that do not permit adequate end-use checks, naming China and Russia, and BIS’s country-level policy for China moved in the opposite direction inside the window (FR 2026-00789, 2026-01-15, Nvidia H200-class semiconductors from presumption of denial to case-by-case).

Cluster negative search BIS-1 (chapter log): a jq pass over all 154 in-window Federal Register records whose agency is the Industry and Security Bureau — every Entity List, Unverified List, Denied Persons, Section 232 and licensing document of the window — plus quoted-phrase Federal Register full-text searches since 2025-01-20, plus the Bureau’s whole active Unified Agenda on reginfo.gov (agencyCd 0600, DOC/BIS: seventeen RINs, each opened and read). Specific queries: "end-use check" (3 in-window documents — the UVL rule, the affiliates interim final rule and a temporary denial order renewal), and the whole Unverified List and Entity List series.

Action
restrict
Object
export licenses to countries barring end-use checks
ID
1852