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On December 23, 2020, the US Department of Commerce s Bureau of Industry and Security ( BIS ) issued a final rule creating a Military End User List ( MEU List ) under the Export Administration Regulations ( EAR ). The final rule also adopted the first tranche of entities added to the MEU List, identifying more than 100 Chinese and Russian entities as Military End Users ( MEUs ).
1 A BIS license is required for certain exports, reexports, and transfers when a party has knowledge that an MEU is a party to the transaction (e.g., as purchaser, intermediate consignee, ultimate consignee, or end user). In a separate action, BIS also removed Hong Kong as a separate destination under the EAR, largely subjecting Hong Kong to the same requirements and restrictions as China.