On June 5, 2020, the US Commerce Department’s Bureau of Industry and Security (BIS) published: (1) a final rule adding nine Chinese entities to the Entity List (the “XUAR Designees”), and (2) a final rule adding twenty four entities located in China, Hong Kong, and the Cayman Islands to the Entity List (the “Military Designees”).

Both sets of designations were announced by the Commerce Department on May 22, 2020 (see announcements here and here), but their designations are effective as of their publication in the Federal Register (June 5, 2020).  The addition of the Military Designees to the Entity List follows BIS’ recent interim final rule amending the end user/end use requirements in the Export Administration Regulations (the EAR) and reflects the same concern surrounding civil and military integration in China (our blog post on this development is available here). However, the recent expansion of the “foreign-produced direct product rule” for Huawei (described in our blog post) does not apply to these newly designated entities.    

Read the rest of this article by Bart M. McMillan, Inessa Owens and Maria Sergeyeva on our Sanctions blog here.