Inclusion of Tranche 4 Military-Affiliated Companies Under Section 1237

January 11, 2021

We have updated our previous dataset of Chinese military companies identified under Section 1237 of the National Defense Authorization Act to reflect the U.S. Department of Defense’s inclusion of four additional entities (Tranche 4) on December 3. This updated dataset contains 73 additional entities we determined are majority-owned by the companies identified in Tranche 4. Our key findings from this expansion are consistent with our initial conclusions – many of these additional entities have no obvious ties to China’s military.

This new expansion was carried out using consistent methodology with the initial dataset. After confirming the legal name and identifying information of the Tranche 4 entities, we ran a set of queries using Sayari’s public records database for all downstream holdings. These initial queries identified 1,772 legal entities linked to the four companies identified by the Defense Department within three layers of ownership, including majority and minority-owned entities, subsidiaries, and company branches. 

We narrowed our initial query per our previous methodology to highlight high risk entities which we define as entities either directly or indirectly majority-owned by the Section 1237 entities, as well as entities explicitly named as “subsidiaries” in China’s Ministry of Commerce Overseas Investment Database. This resulted in 73 entities added in our expanded dataset, for which we’ve included identifying information and other relevant attributes based on available public records last collected in October 2020. 

Please note that due to the limitations iterated in our previous publication, there may be other entities that meet the majority ownership risk threshold which we were unable to identify and thus were omitted from this dataset. Likewise, there may be conflicts between a company’s primary registration record and information disclosed in other official sources such as its annual report. 

Dataset: Chinese Military Companies on Section 1237 & E.O 13959 List

This dataset covers 600+ active legal entities that are majority owned by the 35 Chinese  companies on the Section 1237 and E.O. 13959 list.

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