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DOD Releases List of Additional Companies, In Accordance With Section 1237 of FY19 NDAA

DEC. 3, 2020

Today, the Department of Defense released the names of additional “Communist Chinese military companies” operating directly or indirectly in the United States in accordance with the statutory requirement of Section 1237 of the National Defense Authorization Act for Fiscal Year 1999, as amended.  

The Department is determined to highlight and counter the People’s Republic of China’s (PRC) Military-Civil Fusion development strategy, which supports the modernization goals of the People’s Liberation Army (PLA) by ensuring its access to advanced technologies and expertise acquired and developed by even those PRC companies, universities, and research programs that appear to be civilian entities.  

The Department released its initial list of companies to Congress in June 2020 and will continue to update the list with additional entities as appropriate.

For the list, click here.

For previous lists, click here and here.

The new companies?

China Construction Technology Co. Ltd. (CCTC)
China International Engineering Consulting Corp. (CIECC)
China National Offshore Oil Corp. (CNOOC)
Semiconductor Manufacturing International Corp. (SMIC)

Two comments:

  • Not having a consolidated list – even as simple as what State does for the Cuba Restricted list – is not cool. Harder to maintain, harder to start up a compliance program with… and what will happen if a firm is removed?
  • Imagine this was not China for a moment – but Venezuela. And now imagine that you were doing an asset freeze. Could these company names be identical to those in another country in Latin America – or Spain? And who says these companies must be headquartered in the home country, especially subsidiaries? Would be nice to have something more than a name, wouldn’t it?
And one reminder: Remember that these designations are not active on January 11, 2021 like the original set. All newer designations are live 60 days after their listing – depending on how the math works, it looks like Monday, February 1, 2021.


Defense Department Press Release

December 3, 2020 list of Chinese Military Companies

Categories: Chinese Military Companies sanctions OFAC Updates US Department of Defense updates


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