342 days after the US government blacklisted a Turkish company in a Russia procurement case, it quietly took that company back off the list.
The rule was effective Friday and published Monday!!
CSIS reported in June that the list had gone without a single addition since October 2025, the longest drought since 2008. When it finally moved, it moved twice, and both moves were removals.
The wording BIS published when it listed Atempo on 16th September 2025 was that EB Teknoloji, in conjunction with Atempo, is engaged in concealing shipments of Tier 2 CHPL US origin goods to Russian entities. CHPL is the Common High Priority List, the multilateral list of components that export controllers treat as highest risk of ending up in Russian weapons.
Read the grammar extremely carefully and you might notice interesting things. EB Teknoloji is the subject of that sentence. Atempo is the company it was said to have acted in conjunction with. On Friday the government removed the second name in that sentence and left the subject of it on the list.
Atempo carried footnote 3, the Russian procurement designation, with a licence review policy of denial for everything. Compliance software treats that as a permanent state. It is not permanent. The designation has an exit, and this week BIS opened it.
Opening it took a unanimous interagency vote. The End User Review Committee is Commerce in the chair, with State, Defense, Energy and, where appropriate, Treasury, and a removal carries only if every member agrees. Every member agreed. None of them said why. The rule cites the regulation that lets a listed party ask, and stops there.
The companion rule is smaller and stranger. It deletes two Hong Kong addresses for Arrow Electronics, tidying up after the November 2025 China removals. So the first movement on the list since last October was some housekeeping and a footnote 3 exit.
The asymmetry underneath is structural and nobody prices it. Additions arrive with a press release, a briefing and a name. This removal arrived as a numbered rule with nothing attached to it. The loud channel carries only escalation. The quiet channel carries the reversals. Every sanctions risk model in the market is trained on the loud one.
From 2018 to 2024 BIS added names every 35 days on average. It has now gone ten months without adding one, and came back to subtract.
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