Tag Archives: Entity List

China’s Anti-Foreign Sanctions Law

On June 10, 2021, the People’s Republic of China adopted the Anti-Foreign Sanctions Law (the “Law”). The main purpose of the Law is to provide a legal basis for China to adopt retaliatory measures against any so-called “discriminatorily restrictive measures” that may be imposed by foreign countries against Chinese organizations and citizens (the “Foreign Sanctions”).… Continue Reading

Biden New EO on Chinese Military Companies Creates New Substantive Test for Listing

On June 3, 2021, US President Joseph Biden issued Executive Order 14032, “Addressing the Threat From Securities Investments that Finance Certain Companies of the People’s Republic of China” (EO 14032), substantially amending the prohibitions originally contained in Executive Order 13959 (EO 13959), issued by President Trump on November 12, 2020 (amended January 13, 2021).… Continue Reading

Department of Commerce Takes Action Against Avnet Asia for Involvement in Illegally Transshipping Sensitive U.S. Commodities to China and Iran

On January 29, 2021, Department of Commerce’s Bureau of Industry and Security (BIS) announced an Administrative Settlement of $3.2 million (partially suspended) with Singapore-based Avnet Asia Pte. Ltd. (Avnet Asia), a global distributor of electronic components and related software.… Continue Reading

US Needs to Participate and Lead 5G Standards-setting; Huawei Gets a Pass

On June 18, 2020, the US Department of Commerce, Bureau of Industry and Security (BIS) published in the Federal Register, a new interim final rule that amends the Export Administration Regulations (EAR) (15 CFR Parts 730-774) by excluding from the additional licensing requirements imposed by the designations of Huawei organization on the Entity List releases … Continue Reading

New From BIS: Changes to EAR Direct Product Rule to Tighten Supply Chain for Certain Designated Entity List Organizations

A new Interim Final Rule (New Rule) issued by the US Department of Commerce’s Bureau of Industry and Security (BIS), which amended the Export Administration Regulations (EAR) (15 CFR Parts 730-774) by expanding the direct product rule as applied to certain organizations on the entity list took effect on May 15, 2020. The New Rule, … Continue Reading

US Department of Commerce Adds 28 Chinese Organizations to Its Entity List

In response to ongoing human rights violations, BIS announced that it would add 28 Chinese governmental and commercial organizations to the Entity List for engaging in or enabling activities contrary to the foreign policy interests of the US. This action targets those entities implicated in human rights violations and abuses in China’s campaign targeting Uighurs and other predominantly Muslim ethnic minorities … Continue Reading

Advice for Chinese Companies: How to Cope with Strengthened US Export Controls and CFIUS – Seminars in Shanghai and Beijing – October 2019

Keep US Open to Chinese Business: 维持一个对华企业开放的美国: How to Cope With Strengthened US Export Controls and CFIUS 应对日趋严格的美国出口管制和CFIUS审查的实务指南 Friday, October 11, 2019 – Shanghai (2019 年10月11日,周五 – 上海) Tuesday, October 15, 2019 – Beijing (2019 年10月15日,周二 – 北京)… Continue Reading

US Adds Five Chinese Companies to the Department of Commerce Entity List

On June 24, 2019, the US Department of Commerce, Bureau of Industry and Security (BIS) published in the Federal Register a Final Rule designating five entities, all located in China, to the Entity List. The five entities are: Chengdu Haiguang Integrated Circuit – aliases include Hygon and Chengdu Haiguang Jincheng Dianlu Sheji Chengdu Haiguang Microelectronics Technology – aliases include HMC … Continue Reading

US Commerce Department Offers Huawei and Affiliated Suppliers Interim Reprieve by Granting Temporary General License Until August 2019

On May 22, 2019, the US Department of Commerce, Bureau of Industry and Security (BIS) is expected to publish in the Federal Register a Final Rule creating a 90-day Temporary General License (TGL) for Huawei Technologies Co., Ltd. (Huawei) and the 68 affiliated Huawei entities (collectively, the “Huawei Listed Companies”) that were added to the … Continue Reading

US Adds Huawei and Affiliates to the Department of Commerce Entity List – What to Expect From the Final Rule

On May 21, 2019 the US Commerce Department, Bureau of Industry and Security (BIS) is expected to publish in the Federal Register a Final Rule designating Huawei Technologies Co., Ltd. (Huawei) and 68 affiliated Huawei entities located in 26 countries (collectively, the “Huawei Listed Companies”) to the Entity List. … Continue Reading

BIS Denial Order Against ZTE

Effective 15 April 2018 until 23 March 2025, the US Department of Commerce Bureau of Industry and Security (BIS) imposed a denial order of export privileges against Zhongxing Telecommunications Equipment Corporation of Shenzhen, China (ZTE Corporation) and ZTE Kangxun Telecommunications Ltd. of Hi-New Shenzhen, China (ZTE Kangxun) (collectively, ZTE). Additionally, both entities were added to the BIS Denied Persons List, … Continue Reading

US Commerce and Treasury Departments Add to Lists of Sanctioned Entities Under Russia-/Ukraine-Related Programmes

In June 2017, the Office of Foreign Assets Control (OFAC) and the US Commerce Department’s Bureau of Industry and Security (BIS) imposed coordinated sanctions against two entities from the Crimea Region of Ukraine and eight entities from Russia. OFAC added each entity to the OFAC List of Specially Designated Nationals (SDN List) and Block Persons under the executive orders implemented … Continue Reading

BIS Modifies Entity List Designation

Effective 18 April 2017, the US Commerce Department, Bureau of Industry and Security (BIS) has revised the Entity List entry for Russia’s Federal Security Service (Federalnaya Sluzhba Bezopasnosti or FSB) to conform to the OFAC general license adopted on 2 February 2017, General License No. 1. That general license authorises transactions otherwise prohibited under Executive … Continue Reading

BIS Removes ZTE Corp. From Entity List

The US Department of State’s Bureau of Industry and Security (BIS) has removed from the Entity List China’s telecommunications equipment firms Zhongxing Telecommunications Equipment Corporation and ZTE Kangxun Telecommunications Ltd., known collectively as ZTE. The action follows the agency’s recently announced, record-breaking settlement for US export controls violations, according to which those entities agreed to … Continue Reading

Obama Administration Responds to Russian Hacking With Enhanced Cyber-Related Sanctions

On 28 December 2016, the US President issued Executive Order (EO) 13757 to amend a 2015 EO authorising the US Treasury Department’s Office of Foreign Assets Control (OFAC) to impose sanctions for significant malicious cyber-enabled activities. Intended to address alleged Russian tampering in the US elections, EO 13575 expands the scope of the 2015 EO … Continue Reading

BIS Targeted Large Chinese Telecommunications Company, Then Loosened Restrictions

On 8 March 2016, the BIS added Zhongxing Telecommunications Equipment Corporation (ZTE Corporation), ZTE Kangxun Telecommunications Ltd. (ZTE Kangxun), and two other affiliates to the Entity List (see announcement). However, due to unspecified commitments made by ZTE Corporation and ZTE Kangxun to the US, BIS eased the restrictions imposed against the two entities – but not the affiliates simultaneously designated … Continue Reading

BIS Expands Entity List to Include 29 Persons Acting Contrary to US Policy in the Crimea Region of Ukraine

The US Department of Commerce, Bureau of Industry and Security (BIS) has issued a final rule amending the Export Administration Regulations (EAR) by adding 29 persons to the Entity List. These persons have been determined by the US Government to be acting contrary to the national security or foreign policy interests of the United States … Continue Reading
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