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On December 18, 2020, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a brief press statement announcing that it has “added” more than 60 entities to the Entity List, including Chinese company Semiconductor Manufacturing International Corporation (SMIC), in order to “protect U.S. national security.” The Chinese companies include entities that enable human…

On December 11, 2020, the Treasury Department submitted its first report to Congress under the Hong Kong Autonomy Act, stating that to date it has not identified any foreign financial institutions (FFIs) that have knowingly conducted a significant transaction with an identified foreign person under the Hong Kong Autonomy Act (HKAA). The Department of…

On December 3, 2020, the Department of Defense (DOD) released the names of four additional “Communist Chinese military companies” operating directly or indirectly in the United States in accordance with the statutory requirement of Section 1237 of the National Defense Authorization Act (NDAA) for Fiscal Year 1999, as amended. The companies are:

  • China Construction Technology

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On November 30, 2020, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned and placed on the Specially Designated Nationals (SDN) List China National Electronics Import and Export Corporation (CEIEC). The Treasury Department indicated in a press release that this designation was due to CEIEC’s support for “the illegitimate Maduro regime’s efforts…

On November 25, 2020, the State Department issued a Federal Register Notice announcing the imposition of nonproliferation measures against certain Chinese and Russian entities for the transfer of goods, services, or technology controlled under multilateral control lists (Missile Technology Control Regime, Australia Group, Chemical Weapons Convention, Nuclear Suppliers Group, Wassenaar Arrangement) or otherwise having the…

Key Notes:

  • Executive Order 13959 bans U.S. persons from transacting in publicly traded securities or derivatives or similar securities of any publicly traded Chinese companies designated by the U.S. Department of Defense as enabling Chinese military aims.
  • It also authorizes the secretary of the treasury to identify subsidiaries of the named companies, which will be

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In an early confidential draft of a proposed rule that BIS has shared with a technical advisory committee of industry representatives, trade press is reporting that the Department of Commerce’s Bureau of Industry and Security (BIS) may seek to restrict export transactions with 89 Chinese and 28 Russian companies that are owned or controlled by…

Since April 2020, we have collaborated with our foreign law firm partners to provide a chart summarizing the economic, labor and employment, health and safety, and export and import measures taken by governments around the world in response to the COVID-19 pandemic. After a short break, we are back with version 2.0 of our chart…

On October 29, 2020, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a Federal Register notice announcing further amendments to the Export Administration Regulations (EAR) to revise the license review policy for items controlled for national security reasons destined to the People’s Republic of China (PRC), Venezuela or the Russian Federation (Russia).…

On October 20, 2020, U.S. Customs and Border Protection (CBP) issued a finding determining that stevia extracts and derivatives, mined, produced, or manufactured in the People’s Republic of China (China) by the Inner Mongolia Hengzheng Group Baoanzhao Agriculture, Industry, and Trade Co., Ltd. (Baoanzhao) with the use of convict, forced or indentured labor, are being,…