On August 27, 2020, the US Commerce Department’s Bureau of Industry and Security (“BIS”) issued a final rule (“Final Rule”) adding 24 Chinese state-owned entities to the Entity List (the “SCS Designees”), including several subsidiaries of China Communications Construction Company (“CCCC”), due to their ties to land reclamation efforts involving artificial islands in the South China Sea. In a press statement released with the designations, the Commerce Department cited the role played by the SCS…
China governs the import and export of technology under the Regulations for the Administration of the Import and Export of Technology (“Technology Regulations”), the Measures for the Administration of Technologies Prohibited or Restricted from Import, and the Measures for the Administration of Technologies Prohibited or Restricted from Export. The Technology Regulations and related measures are separate and distinct from other China regulatory regimes that currently govern the import and export of dual-use items and encryption…
On June 26, 2020, the US Commerce Department’s Bureau of Industry and Security (“BIS”) issued 32 Frequently Asked Questions (“FAQs”) to clarify the military end use/user (“MEU”) rules that were published on April 28, 2020 and took effect on June 29, 2020. These rules are intended to combat efforts by entities in China, Russia, and Venezuela to use certain US technologies obtained through civilian supply chains to develop weapons, military aircraft, and surveillance technology contrary to…
On June 5, 2020, the US Commerce Department’s Bureau of Industry and Security (“BIS”) published: (1) a final rule adding nine Chinese entities to the Entity List (the “XUAR Designees”), and (2) a final rule adding twenty four entities located in China, Hong Kong, and the Cayman Islands to the Entity List (the “Military Designees”). Both sets of designations were announced by the Commerce Department on May 22, 2020 (see announcements here and here), but…