How to Use Public Data To Identify Potential Chinese Military End Users

11/10/21 4 minute read

How can you use public data to identify potential Chinese military end users and why is it important? U.S. regulators have emphasized the risks of doing business with Chinese military-industrial complex companies, including the U.S. Department of Commerce’s Bureau of Industry and Security with its updated Military End User (MEU) guidance.

But identifying potential Chinese military end users poses a challenge for export control and due diligence teams. China’s military-civil fusion policy utilizes the private sector to develop dual-use goods and technologies. This means that, in theory, any company in the private sector could supply goods or technologies to the Chinese military.

Public data can surface hidden military end use risk. Tune in as Sayari Senior Analyst Alex Bate explains the complex world of Chinese military companies and walks through three specific techniques for identifying potential Chinese military end users using public data.

You will learn:

How to determine whether a Chinese company is owned by an entity on the NS-CMIC, Section 1237, Section 1260H, BIS Military End User or other watchlist

The U.S. government has published multiple lists of Chinese companies involved in supporting China’s defense sector. Many of these companies own hundreds of subsidiaries, any of which could be a military end user.

How to assess whether a Chinese company has investment from high-risk, government-led military-civil fusion investment funds

Military-civil fusion investment funds are one way the Chinese government pools money toward dual-use technologies. Companies with direct or indirect investment from one of these funds may qualify as a military end user.

How to determine whether a Chinese company is located at a military- civil fusion innovation zone, and why innovation zones matter

A Chinese company’s address can reveal information about its business activities, including ties to military-civil fusion. Operating out of a military-civil fusion innovation zone is another red flag for potential military end use risk.

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