China’s Export Control Law (“ECL”) came into effect on 1 December 2020, providing a framework to a series of separate administrative regulations on export controls issued prior to the law’s enactment. While no implementing rules or regulations under the ECL have been enacted since its passage into law, China’s Ministry of Commerce (“MOFCOM”) recently released Announcement No. 10 of 2021, on “Internal Compliance Guidelines on the Export of Dual-Use Items” (hereafter, the “Guidelines”) pursuant to…