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Export Restrictions Imposed on Five Mainland Chinese Entities

The U.S. Department of Commerce’s Bureau of Industry and Security has issued a final rule that effective 24 June adds five entities under the destination of mainland China to the Entity List, which lists entities restricted from receiving U.S. exports of goods controlled under the Export Administration Regulations. This rule also modifies the listing for one entity under the destination of mainland China.

The new entries consist of the following five mainland Chinese entities for which BIS has reasonable cause to believe, based on specific and articulable facts, that they have been involved, are involved or pose a significant risk of being or becoming involved in activities that are contrary to the national security or foreign policy interests of the United States.

  • Chengdu Haiguang Integrated Circuit, including two aliases (Hygon and Chengdu Haiguang Jincheng Dianlu Sheji)
  • Chengdu Haiguang Microelectronics Technology, including two aliases (HMC and Chengdu Haiguang Wei Dianzi Jishu)
  • Higon, including five aliases (Higon Information Technology, Haiguang Xinxi Jishu Youxian Gongsi, THATIC, Tianjing Haiguang Advanced Technology Investment and Tianjing Haiguang Xianjin Jishu Touzi Youxian Gongsi)
  • Sugon, including nine aliases (Dawning, Dawning Information Industry, Sugon Information Industry, Shuguang, Shuguang Information Industry, Zhongke Dawn, Zhongke Shuguang, Dawning Company and Tianjin Shuguang Computer Industry)
  • Wuxi Jiangnan Institute of Computing Technology, including two aliases (Jiangnan Institute of Computing Technology and JICT)

BIS is also modifying the existing entry for National University of Defense Technology (NUDT) to add one alias (Hunan Guofang Keji University) and four locations.

For these entities, BIS is imposing a licence requirement for exports of all items subject to the EAR and a licence review policy of presumption of denial. This requirement applies to any transaction in which items are to be exported, re-exported or transferred (in-country) to any of these entities or in which they act as purchaser, intermediate consignee, ultimate consignee or end-user. In addition, no licence exceptions are available for exports, re-exports or transfers (in-country) to these entities.

Shipments of items removed from licence exception eligibility or for export or re-export without a licence (NLR) as a result of this rule that were en route aboard a carrier to a port of export or reexport on 24 June pursuant to actual orders for export or re-export to a foreign destination may proceed to that destination under the previous licence exception eligibility or without a licence.

Content provided by Picture: HKTDC Research
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