Dataset: At-Risk, Non-Obvious Subsidiaries of BIS-Listed Chinese Military End Users in Tech, Aerospace, & Metals

U.S.-identified Chinese military end users (MEUs) control more than 80 previously unnamed entities, according to our public records analysis. These companies, while not explicitly named as MEUs, may be at risk of directly or indirectly supporting China’s military.

BIS names Chinese military end users

In December 2020, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) published the names of 58 Chinese entities determined to be “military end users.” MEUs are entities that support the operation of a military item. In China, U.S.-designated MEUs include public research institutes and private companies.

BIS stressed that their list was “not exhaustive” and has called for due diligence into MEUs’ broader corporate networks, according to an FAQ from January.

Using graph analytics to uncover additional risk through ownership

Using Chinese public records in Sayari Graph, we identified the 58 Chinese MEUs named by BIS, plus their subordinate institutions. We then identified these entities’ majority-owned subsidiaries within three layers of ownership. This resulted in a list of 86 companies controlled by BIS-identified MEUs. (Note: we ran a similar analysis on Section 1237 Chinese military companies in December 2020.)

Ties to MEUs are not always obvious

Like their owners, these subsidiaries mostly operate in tech, aerospace, and metals. Their names or business purposes do not directly reference the Chinese military. This is not surprising: military-civil fusion policies, by definition, rely on private and civilian companies.

Moreover, many do not reference their parent company in their company name, meaning that their ties to known MEUs are not obvious without scrutiny into their ownership and corporate network.

BIS Chinese Military End Users

Request our accompanying dataset for highest-risk companies owned by the 58 Chinese entities on the Bureau of Industry and Security Military End User list

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