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On October 19, 2024, China formally published the new Regulations on Export Control of Dual-Use Items (“Regulations”), which will take effect on December 1, 2024. These Regulations which are aimed at implementing the dual-use export controls under the Export Control Law (“ECL”) introduced in 2020, will replace the existing two-decade-old legacy regulations on dual-use export controls. Compared to the legacy regulations, these new Regulations are more closely aligned with the ECL framework and contain implementation…

On 26 December 2023, China’s Ministry of Foreign Affairs announced new sanctions measures under the Anti-Foreign Sanctions Law against the following parties for their involvement in the imposition of US restrictive measures on Chinese entities over their links to alleged human rights abuses in the Xinjiang Uygur Autonomous Region: The sanctioned parties are prohibited from entering China (including mainland and the Hong Kong and Macao Special Administrative regions). In addition, all properties (including movable and…

On April 12, 2023, China’s regulators on cybersecurity and product standardization, including the Cyberspace Administration of China (“CAC”), Ministry of Industry and Information Technology (“MIIT”), Ministry of Public Security (“MOPS”), Ministry of Finance (“MOF”) and the China National Certification and Accreditation Administration (“CNCA”), jointly published a Circular to announce the following changes to the licensing regimes for network products distributed in the Chinese market: The above changes are a manifestation of the Chinese regulators’ efforts…

Background After two and a half years since the issuance of the Regulations on the Unreliable Entities List (“UEL Regulations”), the Unreliable Entities List Working Mechanism (“Mechanism”) headed by China’s Ministry of Commerce has for the first time designated two US aerospace and defense companies as “Unreliable Entities”. The notice issued by the Mechanism on February 16, 2023 announced the below measures against these Unreliable Entities: This comes in addition to the announcement made by…