BIS Adds 125 Entities to Entity List, Imposes Black Mass and Tungsten Export Controls

The US Bureau of Industry and Security added 63 entities in Russia, 42 in China, 11 in Iran, and eight in Türkiye to the Entity List for Russia-related export control violations — effective August 27 — per the Sandler, Travis & Rosenberg analysis of BIS actions. Simultaneously, a BIS temporary final rule effective today requires US persons selling black mass (battery recycling material) and tungsten waste and scrap to allocate 100% of monthly sales to US persons absent an adjustment or exception, targeting critical mineral flows to China and Russia. The Russia/Belarus military end-user foreign direct product rule was also expanded to cover transshipment of US-branded microelectronics manufactured outside the US. These layered actions mean that exporters, trading companies, and logistics providers with any Russia, China, or Iran-adjacent supply chains must conduct fresh Entity List screening as of today's date. Baker McKenzie's Global Sanctions and Export Controls Blog flagged the rule as entering force today, making August 27 a live compliance deadline.