Eight New Hong Kong Addresses are Sanctioned under the BIS Entity List Rules

Jason Dickstein

June 12

The United States Government has listed eight addresses in Hong Kong as denied destinations under the BIS entity list rules.

The United States Government has found that shell companies are a concern when it comes to diversion of exported goods to illegal destinations. In some cases, the United States will sanction a company, and the people involved may simply create a new corporate entity to do business with the United States.

BIS is targeting the shell company service industry by creating a new regulatory framework for listing addresses on the BIS Entity List. These are addresses that the United States has identified as presenting a high risk of involvement in unlawful diversion. By listing these addresses, the U.S. hopes that it will be harder for shell companies to find a corporate services provider who is willing to lend the use of their address for unlawful trade.

BIS is adding eight addresses in Hong Kong to the Entity List. Going forward, any company at such an address will be considered to be a denied entity. The addresses are:

Address 01: Unit D, 16/F One Capital Place, 18 Luard Rd, Wan Chai, Hong Kong.
Address 02: Unit 04, 7/F Bright Way Tower, No. 33 Mong Kok Road, Kowloon, Hong Kong.
Address 03: Room 19C Lockhart Centre 301-307, Lockhart Rd. Wan Chai, Hong Kong.
Address 04: Room 803, Chevalier House 45-51, Chatham Road South, Tsim Sha Tsui, Hong Kong.
Address 05: Flat/RM 2309, 23/F, Ho King Commercial Centre, 2-16 Fa Yuen Street, Mong Kok, Kowloon, Hong Kong.
Address 06: Office 4, 16/F Ho King Commercial Centre, 2-16 Fayuen Street, Hong Kong.
Address 07: Room 1318-19, 13F, Hollywood Plaza, 610 Nathan Road, Mong Kok, Kowloon, Hong Kong.
Address 08: Room 1318-20, 13F, Hollywood Plaza, 610 Nathan Road, Mong Kok Kowloon, Hong Kong.

We have promoted the search for addresses in the past as an element of due diligence when vetting your export partners. This formalizes a requirement to assess addresses.

ACTION: Check the address of each partner in your export transaction (including each Purchaser, Intermediate Consignee, Ultimate Consignee, and End-User) against the consolidated export screening list.

NOTE: As of today, plugging one of the above addresses, alone, into the consolidated export screening list will yield a list of the sanctioned businesses at that address. It does not (yet) reveal that the address (itself) has been sanctioned. We expect BIS to soon implement a more explicit address-based warning for when you search on a restricted address.

The new listings are expected to be effective as of today (June 12), but the Federal Register Notice is scheduled to be published next week on June 18. A pre-publication version of the listings and related rule change (to support the use of addresses) is currently available online.