On July 9, 2021, The Department of Commerce (DOC) determined that 23 Chinese companies took actions contrary to the foreign policy interests of the United States and were added to the Entities List. The Bureau of Industry and Security (BIS) noted that it “publishes the names of certain foreign persons – including businesses, research institutions, government and private organizations, individuals, and other types of legal persons – that are subject to specific license requirements for the export, re-export and/or transfer (in-country) of specified items.” The BIS also notes that “These persons comprise the Entity List, which is found at Supplement No. 4 to Part 744 of the Export Administration Regulations (EAR).”

Of the 23 companies added to the list, 14 were accused of direct involvement in human rights abuses in Xinjiang, 4 of supporting the Chinese military’s modernization programs, 4 of violating U.S. sanctions, and 1 of procurement of U.S.-origin items for unauthorized military end-use. The list below, as outlined by the July 12, 2021, BIS rule highlights the additions:

The End-User Review Committee (ERC) added the following 14 entities to the Entity List for being implicated in human rights violations and abuses in the implementation of China’s campaign of repression, mass detention, and high-technology surveillance against Uyghurs, Kazakhs, and other members of Muslim minority groups in the Xinjiang Uyghur Autonomous Region (XUAR).

  1. China Academy of Electronics and Information Technology
  2. Xinjiang Lianhai Chuangzhi Information Technology Co., Ltd.
  3. Leon Technology Co., Ltd.
  4. Xinjiang Tangli Technology Co., Ltd.
  5. Shenzhen Cobber Information Technology Co., Ltd.
  6. Xinjiang Sailing Information Technology Co., Ltd.
  7. Beijing Geling Shentong Information Technology Co., Ltd.
  8. Tongfang R.I.A. Co., Ltd.
  9. Shenzhen Hua’antai Intelligent Technology Co., Ltd.
  10. Chengdu Xiwu Security System Alliance Co., Ltd.
  11. Beijing Sinonet Science & Technology Co., Ltd.
  12. Urumqi Tianyao Weiye Information Technology Service Co., Ltd.
  13. Suzhou Keda Technology Co., Ltd.
  14. Xinjiang Beidou Tongchuang Information Technology Co., Ltd.

The ERC added the following 4 companies to the Entity List for activities related to acquiring or attempting to acquire U.S.-origin items in support of military modernization for the People’s Liberation Army.

  1. Hangzhou Hualan Microelectronics Co., Ltd.
  2. Kyland Technology Co., Ltd.
  3. Kyland subsidiary Armyfly
  4. Kyland subsidiary Kindroid

The ERC added the following 4 companies to the Entity List for exporting or attempting to export items subject to the EAR to an entity on the U.S. Department of the Treasury’s Office of Foreign Asset Control Specially-Designated Nationals List without the necessary licenses.

  1. Beijing Hileed Solutions Co., Ltd.;
  2. Beijing E-Science Co., Ltd.;
  3. Info Rank Technologies; and
  4. Wingel Zhang

The ERC added the following company to the Entity List for exporting or attempting to export items subject to the EAR related to the procurement of U.S.-origin items for unauthorized military end-use.

  1. Wuhan Raycus Fiber Laser Technologies Co., Ltd.

A full copy of the federal register notice is available here.

For more information on actions addressing human rights, forced labor abuses, and export controls, contact our team and see previous posts below.

Forced Labor/U.K. Modern Slavery Act Archives | International Trade Law (cmtradelaw.com)

Xinjiang Archives | International Trade Law (cmtradelaw.com)

Bureau of Industry and Security (BIS) Archives | International Trade Law (cmtradelaw.com)

Export Administration Regulations (EAR) Archives | International Trade Law (cmtradelaw.com)

Export Controls Archives | International Trade Law (cmtradelaw.com)

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