Blog Posts

Tracking and Comparing Chinese Military Companies Appearing on Different U.S. Regulatory Watchlists

06/16/21 4 minute read

Over the past year, the U.S. has repeatedly targeted Chinese companies supporting China’s military through its military-civil fusion strategy.

As of June 2021, there are four distinct U.S. government watchlists of Chinese military companies, each with different purposes and tied to different restrictions:

  • Section 1237 List, issued by the Department of Defense
  • Section 1260H List, issued by the Department of Defense
  • Non-SDN Chinese Military-Industrial Complex Companies List (NS-CMIC), issued by the Department of the Treasury
  • Military End User List, issued by the Department of Commerce

We have summarized last week’s changes and compiled a master list of all U.S.-named Chinese companies and the corresponding list/s on which they appear, with additional identifiers from Chinese public records to help compliance and investigation teams more easily respond to these regulations.

Recent actions against Chinese military companies

On June 3, President Biden signed a new Executive Order (E.O.) amending E.O. 13959, which names 59 companies determined by the Department of the Treasury to be assisting China’s military development.

On the same day, the Department of Defense (DoD) released a list of 47 Chinese military companies with direct or indirect activities in the United States, in accordance with Section 1260H of the National Defense Authorization Act (NDAA) of 2021.

Both lists are continuations of the Chinese military companies identified by DoD last year under Section 1237 of the NDAA of 1999. The Section 1237 list served as the focal point for regulatory action aimed at entities believed to be involved in Chinese military development.

While there is significant overlap between these lists, they are tied to separate regulations that monitor or bar investment and trade.

Which Chinese companies are on which list?

We have compiled a master list of all entities appearing on these three U.S. regulatory lists associated with Chinese military companies, as well as the Bureau of Industry and Security’s (BIS) Military End User List. We have marked which public list each company appears on, making it easy to track what regulations currently apply to each entity.

We have also included identifiers from Chinese public records to help disambiguate these companies, including company names and addresses in both English and Chinese, ID numbers, and descriptions of business purposes as entered on company registries.

You can download and reference that list here.

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