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Entity List

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On December 22, 2020, the US Commerce Department’s Bureau of Industry and Security (“BIS”) published a final rule (“Final Rule”) in the Federal Register adding 77 entities and individuals to the Entity List, including several prominent Chinese multinationals (together, the “Designees”). The Final Rule took effect on December 18, 2020. On the same day, BIS also published FAQs related to its recent expansion of the foreign-produced direct product rule (the “Huawei FPDP Rule”). Entity List Designations In press…

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…