In recent years, increasing numbers of non-US companies have found themselves in the sights of both the US Commerce Department’s Bureau of Industry and Security (“BIS”) and Treasury’s Office of Foreign Assets Controls (“OFAC”), with additions to the Military End-User List or the EAR’s Entity List. While those companies have not been exclusively Chinese – in December, additions to the Entity List included companies from Georgia, Malaysia and Turkey – Chinese companies have made up the bulk ...
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