US Makes Major China Watchlist Changes With No Public Announcement

Newly watchlisted Sun Yat-Sen University in Guangzhou, China.

Newly watchlisted Sun Yat-Sen University in Guangzhou, China.

The US Department of Commerce’s Bureau of Industry and Security (BIS) has taken three actions in the last four days, adding 29 names and removing 40 from its export watchlists, including several major Chinese companies and universities, without announcing these actions to the public. This is a significant departure from common procedures used by the US government, including the Department of Commerce, where watchlist actions are almost always accompanied with press releases and notification emails. Being added or removed from such a list can make or break a company, and it is especially unusual as the actions include large removals and additions. The timing of the actions is as follows:

  • Friday, 30 October 2020 at 12:41 EST: 26 names added, 40 names removed from Unverified List

  • Friday, 30 October 2020 at 17:41 EST: 1 name added to Denied Persons List

  • Monday, 2 November 2020 at 10:41 EST: 2 names added to Denied Persons List

  • Total: 29 names added, 40 names removed.

There is absolutely no press coverage or analysis of these actions, despite several of the Commerce BIS removals and additions being major names. There is a Federal Register Notice dated October 9 for the large action (not the two smaller ones), but these notices are hard to view or find unless linked to, which explains the total lack of awareness surrounding these actions. The Federal Register Notice also raises the question of why it was published on October 9, but the 26 additions and 40 removals not added to the public database until 21 days later.

 

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The removals include two major Chinese universities: Xi'an Jiaotong University and Shanghai Institute of Applied Physics Chinese Academy of Sciences, as well as Runtop Circuits Technology Co., a general trading company in Hong Kong with no internet presence. The additions to the list include Sun Yat-Sen University, a major research university in Guangzhou, China.

This is the second recent issue with Commerce watchlists. In August, Commerce published a press release announcing the addition of 24 companies, but did not actually add them to its database until later, leading to confusion amongst compliance professionals who could not find the named companies in the official database or in their vendor-provided systems. This time the situation is inverted. Changes have been made in the database, but there is no corresponding press release or email alert. To check Commerce’s public watchlist database for the added names go here: https://legacy.export.gov/csl-search or request a Castellum.AI account by emailing contact@castellum.ai .

See below for a full list of ALIASES that were added and removed from the US Commerce BIS Unverified List.  As these are ALIASES, there are more than 29 in the added column, and more than 40 in the removed column. 


Friday, 30 October 2020 at 17:41 EST | BIS Denied Persons List
1 alias added: Abdul Majid Saidi


Monday, 2 November 2020 at 10:41 EST | BIS Denied Persons List
2 aliases added: Patrick Germain, Oswaldo Sanchez


Friday, 30 October 2020 at 12:41 EST | BIS Unverified List

26 entries added (27 aliases)

  1. Aelcomp OY

  2. Aero King FZC

  3. Atlas Sanatgaran

  4. AW Industrial Ltd

  5. DMA Logistics GmbH

  6. Elemental Lab

  7. Emax Technology Co Ltd HK

  8. ENGRO Polymer & Chemicals Ltd

  9. Fast Aviation

  10. Fortune International Trading

  11. Halm Elektronik GmbH

  12. Integrated Production and Test Engineering

  13. Intertranslog OY

  14. Iranian & Armenian

  15. Kenwoo International Trade Company

  16. Lavender General Trading

  17. Metafor Lojistik

  18. Naina Exporters and Importers

  19. Piricas Trading Company

  20. Rising Sun FZE

  21. Sea Prince Logistics LLC

  22. Seven Star Company

  23. Shanghai Institute of Applied Physics, Chinese Academy of Sciences

  24. Sun Yat-Sen University

  25. Universal Logistics Systems GmbH

  26. VIP Technology Ltd.

  27. Xiang Cheng Gao Trading (HK) Ltd


Friday, 30 October 2020 at 12:41 EST | BIS Unverified List

40 entries removed (43 aliases)

  1. Advent International Limited

  2. Aisin Nantong Technical Center

  3. AST Technology Group (HK) Ltd.

  4. Beijing Institute of Nanoenergy and Nanosystems

  5. Changchun Institute of Applied Chemistry, Chinese Academy of Sciences

  6. Chepstow FZE

  7. CITI Hong Kong Ltd

  8. Foot Electronics Co. Ltd.

  9. Fuiyen Technology Ltd.

  10. GA Industry Co. Ltd.

  11. Global Sourcing Electronics (HK) Ltd.

  12. GS Technology Group Ltd.

  13. GS Technology Ltd.

  14. Hi-Shine Technology (HK) Limited

  15. Hong Kong U.Star Electronics Technology Co. Ltd.

  16. Hong Kong U.Star Electronics Technology Co., Ltd.

  17. Hua Fu Technology Co. Ltd.

  18. Institute of Geology, Chinese Academy of Geological Sciences

  19. Microlink Communication Ltd.

  20. Milectronic Communication Ltd.

  21. Newplus Equipment Ltd.

  22. Ningbo Zhongxian Optoelectronic Technology Co, Ltd.

  23. People Tele-com Group

  24. PetroChina International Jabung Ltd

  25. Renmin University

  26. Runtop Circuits Technology Co.

  27. Shanghai Institute of Applied Physics Chinese Academy of Sciences

  28. Shanghai Institute of Technical Physics Chinese Academy of Sciences

  29. Shanghai SKEQI Automation Engineering Co.

  30. Shi Jia Zhuang Suin Instruments, A-2 No. 99 Yuyuan Road, LuQuan District, Shijiazhuang, China 050000

  31. Team Kingdom Limited

  32. Termei Torch & Tip Company

  33. Tianao Electronics Limited

  34. Tongji University

  35. Top-Rank Int Trade (HK)

  36. Vessel Technology Limited

  37. VIP Technology Ltd., Bechtereva Street 3/2, Office 40, Saint Petersburg, Russia

  38. Win Electronics Limited

  39. Win-Semi International Ltd

  40. Xi'an Caijing Opto-Electronics Science and Technolgoy Co., Ltd

  41. Xi'an Jiaotong University

  42. Xi'an Micromach Photon Manufacture Technology

  43. Yunnan Observatories, Chinese Academy of Sciences

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