A final rule will be published in the Federal Register on December 22, 2020 adding 77 entities to the BIS Entity List. Among these are several Chinese companies, most notable for many of our clients is Semiconductor Manufacturing International Corporation (SMIC). A license is required for all exports to entities on the Entity List, which will be reviewed with a presumption of denial. https://wilmarth-associates.com/restrictions-on-commercial-exports-to-china/
We are also awaiting the release of the official list of Chinese, Russian, and Venezuelan “Military End-Users” in the near future and will post a link to that list when it is released. We continue to warn you to be vigilant in vetting your Chinese customers and in receiving end use statements to assure that items will not be re-exported to Chinese military end users or any sanctioned party.
This Blog is made available by Wilmarth & Associates for educational purposes as well as to give you general information and a general understanding of export law and compliance, not to provide specific legal advice. This blog is not legal advice and should not be treated as such. You must not rely on this blog as an alternative to legal advice from your attorney or other professional legal services provider. The information provided on this website is presented “as is” without any representations or warranties, express or implied.