On Thursday, May 9, 2024, the U.S. Department of Commerce Bureau of Industry and Security (BIS) added 37 Chinese entities to the Entity List. Among them were technology companies (predominately those tied to quantum computing), manufacturing firms, and research institutions. No person may export, reexport, or transfer any items subject to the Export Administrative Regulation (EAR) to these persons without a license.   BIS will review any license requests from these entities with a presumption of denial.

BIS designated these parties because they: (i) shipped U.S. controlled items to Russia, (ii) attempted to acquire controlled items to aid China’s military or quantum technologies capabilities, or (iii) had ties to, or were involved with, China’s “High Altitude Balloon” that overflew the United States in February 2023. These additions are part of the U.S.’s broad strategy to impede both China’s access to critical and emerging technologies (CET) and deter support for Russia’s invasion of Ukraine. Last week the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued new sanctions on Chinese (and other) entities supporting Russia’s invasion of Ukraine.

If you have any questions about the recent additions to the BIS Entity List, contact Crowell’s International Trade Team.