Master Class:
Chinese military companies identified under Section 1237

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Date:Wednesday, March 10, 2021
Time:1:00 PM ET / 18:00 UTC
Length:60 Minutes
Cost:Free

 

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We have curated a structured dataset of the highest-risk entities owned by Chinese military companies on the Section 1237 and E.O. 13959 list

This dataset is designed to help affected industries simplify the screening and due diligence process for export controls and trade compliance, focusing on 600+ legal entities that are more than 50% owned by the designated Chinese military companies.

Recent Posts:

Addition of Tranche 5 Military-Affiliated Companies Under Section 1237, E.O. 13959

We have updated our dataset of Chinese military companies identified under Section 1237 of the National Defense Authorization Act to reflect the U.S. Department of Defense’s addition of nine entities on January 14. The updated dataset also includes 34 entities we determined to be majority-owned by the companies identified in Tranche 5. We have determined that these additional entities do not have obvious ties to China’s military.

Inclusion of Tranche 4 Military-Affiliated Companies Under Section 1237

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.

How to Identify Military-Civil Fusion Companies in China Using Public Records

Recent regulatory actions compel financial institutions and multinationals to identify Chinese entities with ties to the People’s Liberation Army (PLA) and those that participate in the strategic policy of Military-Civil Fusion (MCF). Our analysis of entities designated by the Department of Defense as “Communist Chinese military companies” and 25,000+ of their downstream entities showed that only a few had overt military affiliations in their names and declared business purposes.

Identifying High-Risk Entities Owned By “Chinese Military Companies” on Section 1237 & E.O. 13959 List

13th Recent U.S. regulations have targeted the risks posed by Chinese military companies, including 31 companies designated by the Department of Defense under Section 1237 of the National Defense Authorization Act of 1999 and later named in Executive Order 13959 (“the Section 1237 list”).

These actions expand the definition of military affiliated entities in China and present new challenges for compliance teams.

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