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Rounding out an already-intense 2020, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued three notices in December that expanded export sanctions and restrictions against Chinese, Russian, and other enterprises and institutions accused of engaging in activities contrary to U.S. interests. On December 18, BIS announced export sanctions against Semiconductor Manufacturing International Corporation (“SMIC”), the largest semiconductor producer in the People’s Republic of China (“PRC”), along with 76 other entities, the vast majority of which are PRC enterprises and research institutes. On December 23, BIS created a new Military End User (“MEU”) List that designates specific PRC and Russian entities for more stringent export licensing requirements under the MEU rule expanded by BIS earlier in the year. Finally, also on December 23, BIS officially terminated Hong Kong’s s
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The United States continues to tighten controls on the People’s Republic of China. In this article we address three regulatory changes that highlight the need for enhanced due diligence when dealing with China: 1) restrictions on recent additions to the Entity List; 2) controls on military end-uses and military end-users; and 3) elimination of Hong Kong as a separate destination under the Export Administration Regulations (EAR).
Entity List
On December 22, 2020, the Bureau of Industry and Security (BIS) added 59 Chinese entities to the Entity List, thereby expanding the licensing requirements on export transactions with these entities. See Notice at 85 Fed. Reg. 83416. The additions to the Entity List are the result of the collective determination by the Departments of Commerce, State, Defense, Energy, and where appropriate, the Treasury (collectively, the “End-User Review Committee”) that these entities are engagi
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Rescuers unload relief supplies in Shuangshi township, Lushan County of Ya’an, Sichuan province, April 24, 2013. Tens of thousands of homeless survivors of China’s most recent devastating quake are living in makeshift tents or on the streets, facing shortages of food and supplies as well as an uncertain future.
Earth Moves, China Rallies
May 4, 2013
By Caixin staff reporters Xie Haitao, He Xin, and Chen Baocheng, with Zhang Tao in Ya’an; Wang Xiaoqing, Cui Zheng, Wang Jing, and Liu Hongqiao in Beijing; and Yu Dawei in Shanghai
Rapeseed was ripening in the lush fields ringing the village of Renjia when a local farmer, forced from his home, stepped into the sea of green stalks and pitched a tent.