On 28 April, China’s Ministry of Commerce (“MOFCOM”) released an updated version of the Guiding Opinion of the Ministry of Commerce on the Establishment of Internal Compliance Mechanism for Export Controls on Exporters of Dual-Use Items (“Order No. 10”). Order No. 10 was first published in August 2007 (then, as “Order No. 69”); MOFCOM indicated in December 2020 that it would update the guidelines in line with the new Export Control Law (“ECL”).
In a client briefing, lawyers at Crowell & Mori...
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