On August 28, 2020, the U.S. Department of Defense (DOD) updated its list of “Communist Chinese military companies” that provide expertise and technological support to the Chinese military. The list, which includes a number of large state-owned enterprises in China, does not impose sanctions or export restrictions on the listed companies, although some of the companies are separately included on the Bureau of Industry and Security’s (BIS) Entity List.
Exporters should use the DOD list as a due diligence tool to identify customers and end users that may be subject to BIS’s recently expanded military end user and end use export controls. Under those rules, U.S. and non-U.S. companies require licenses to ship certain items subject to U.S. control rules to military end users or military end uses in China.
Please let us know if you have any questions about the BIS military end use rule or the updated DOD list.