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Entity List

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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…

On August 17, 2020, the US Commerce Department’s Bureau of Industry and Security (“BIS”) issued a final rule (“Final Rule”) (i) expanding the Export Administration Regulations (“EAR”) General Prohibition Three (the foreign-produced direct product rule, or the “FPDP Rule”) to further restrict Huawei Technologies Co. Ltd. and its affiliates designated on the BIS Entity List (collectively, “Huawei”) from acquiring foreign-produced semiconductors that are the direct product of certain US software and technology, (ii) removing the…

On July 22, 2020, the US Commerce Department’s Bureau of Industry and Security (“BIS”) published a final rule (“Final Rule”) adding eleven Chinese entities to the Entity List (the “XUAR Designees”) due to their alleged involvement in human rights abuses including mass arbitrary detention, forced labor, involuntary collection of biometric data, and genetic analyses targeted at Muslim minority groups in the Xinjiang Uyghur Autonomous Region (“XUAR”). The Final Rule also provided modifications and revisions of thirty-seven existing entries on…

On June 15, 2020, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) published an interim final rule (“Interim Final Rule”) effective on June 18, 2020 to authorize the limited release of certain items subject to the Export Administration Regulations (“EAR”) to Huawei and its affiliates listed on the BIS Entity List (“Huawei Listed Entities”) in the context of international efforts to develop technical standards for 5G and other new technologies. In a…