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Tina Li

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On November 2, 2021, Ministry of Commerce of China (“MOFCOM”) officially released the revised Catalogue of Technologies Subject to Import Prohibition and Restriction (“Technology Catalogue”), effective immediately, which identifies, among others, foreign “data encryption technology employing a key length greater than 256 bits” as a technology that requires import permit when transferred to a Chinese party. This new development may significantly impact multinational corporations’ supply chain operations that involve cross-border transfer of encryption technologies. As…