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BIS Adds 33 Chinese Companies to the Entity List

By Chandler Leonard on May 29, 2020
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Secretary of Commerce Ross announced the Entity List additions on Friday, May 22, 2020, via separate press releases, citing 24 of the entities for “represent[ing] a significant risk of supporting procurement of items for military end-use in China,” and the remaining 9 entities for their complicity in human rights violations in the Xinjiang Uighur Autonomous Region (XUAR).

The addition of the 24 entities apparently supplying US commodities and technologies for military end use follows BIS’ recent interim final rule amending the Export Administration Regulations (EAR) § 744.21 end user/end use requirements, and appears to arise from the same U.S. concern surrounding civil and military integration in China. The entities include governmental and commercial organizations based in China, Hong Kong, and the Cayman Islands.

The 9 entities added for their reported ties to abuses in the XUAR include the PRC Ministry of Public Security’s Institute of Forensic Science, as well as eight Chinese companies, and form the second tranche of entities listed by BIS explicitly for human rights violations.

Pursuant to § 744.11(b) of the EAR, BIS may add entities to the Entity List for “which there is reasonable cause to believe, based on specific and articulable facts, that the entity has been involved, is involved, or poses 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…”

Though Ross’ statements do not specify, it seems likely the additions will impose an export licensing requirement for all items subject to the EAR to the newly listed entities, though exports to the 9 human-rights related additions will likely include the same case-by-case standard of review for licensing of specified ECCNs.

Photo of Chandler Leonard Chandler Leonard

Chandler S. Leonard is an associate in Crowell & Moring’s Washington, D.C. office and a member of the firm’s International Trade Group. Chandler’s practice focuses on export controls and economic sanctions issues, including voluntary disclosures and enforcement matters before the Departments of Commerce…

Chandler S. Leonard is an associate in Crowell & Moring’s Washington, D.C. office and a member of the firm’s International Trade Group. Chandler’s practice focuses on export controls and economic sanctions issues, including voluntary disclosures and enforcement matters before the Departments of Commerce, State, and Treasury. Chandler has experience analyzing and advising U.S. and non-U.S. companies with respect to proposed transfers of U.S. origin technology, software, hardware, and services. She has performed jurisdictional and classification analyses under the ITAR and EAR, including drafting Commodity Jurisdiction requests and CJ Reconsideration requests. She assists in developing and/or reviewing U.S. export and sanctions compliance programs, including risk assessments. Chandler also has experience training a wide variety of audiences, both U.S. and foreign, on compliance with U.S. export control and sanctions requirements.

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  • Posted in:
    Business and Commercial
  • Blog:
    International Trade Law
  • Organization:
    Crowell & Moring LLP
  • Article: View Original Source

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