No, not all sections of Part 744 of the EAR (which defines the criteria for possible inclusion on the Entity List) require that a person’s alleged activity involve items subject to the EAR.  Section 744.11, for example, requires that the person’s activities be contrary to U.S. national security and/or foreign policy interests but does not require that the activities involve items subject to the EAR.

   
© BIS 2016