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The U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) recently announced the addition of 32 Chinese companies and 1 Chinese government agency to the Entity List, citing connections to items for military end-use and human rights abuses against Uighur Muslims in the Xinjiang region. The addition of these Chinese entities to the Entity List follows BIS’s rule changes that further restricted the supply of U.S. technology to Huawei and its affiliated entities. This action prohibits the export, reexport or in-country transfer of items subject to the Export Administration Regulations (“EAR”) to the named entities without authorization from the Department of Commerce.

Twenty-four of the companies, based in China, Hong Kong, and the Cayman Islands, were added because they allegedly support procurement of items for military end-use in China. The other nine entities, which includes China’s Ministry of Public Security’s Institute of Forensic Science, were said to be “complicit in human rights violations and abuses committed in China’s campaign of repression, mass arbitrary detention, forced labor and high-technology surveillance against Uighurs, ethnic Kazakhs, and other members of Muslim minority groups in the Xinjiang Uighur Autonomous Region” and will face “new restrictions on access to U.S. technology.”

Husch Blackwell continues to monitor the export controls on China and will provide updates as they become available. We encourage clients and companies to review the linked announcements from BIS and to contact Cortney Morgan or Grant Leach of Husch Blackwell’s Export Controls and Economic Sanctions team with any questions or concerns.