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Frank Pan

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The Ministry of Commerce of China (MOFCOM) announced on 31 May 2019 that the Chinese government will introduce an “Unreliable Entity List” regime, under which foreign entities or individuals that boycott or cut off supplies to Chinese companies for non-commercial purposes and causing serious damages to Chinese companies would be listed as “Unreliable Entities”. The specific rules, including the list itself and the restrictive measures applicable to the listed entities, will be separately released in the near future. This new regime may be used by China as a countermeasure against export control measures of foreign governments targeting specific Chinese companies.

Background On 18 February 2017, China’s Ministry of Commerce and General Administration of Customs jointly issued Announcement [2017] No. 12 (“Announcement No. 12”),  imposing a blanket suspension on imports of coal produced in North Korea for the rest of the year. The suspension includes imports for which applications have been made, but not yet processed by Customs. Announcement No. 12 takes effect from 19 February 2017, and will be effective till 31 December 2017. Announcement…

China has banned exports to the Democratic People’s Republic of Korea (“DPRK”) of technology and materials that might be used in weapons production. The new list of items banned for export to DPRK adds to a list of technologies and goods banned for export released in 2013 by the Commerce Ministry, the Ministry of Industry and Information Technology, and the China Atomic Energy Authority 2013 after DPRK had carried out its third nuclear test that…