US Makes Major China Watchlist Changes With No Public Announcement
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)
Aelcomp OY
Aero King FZC
Atlas Sanatgaran
AW Industrial Ltd
DMA Logistics GmbH
Elemental Lab
Emax Technology Co Ltd HK
ENGRO Polymer & Chemicals Ltd
Fast Aviation
Fortune International Trading
Halm Elektronik GmbH
Integrated Production and Test Engineering
Intertranslog OY
Iranian & Armenian
Kenwoo International Trade Company
Lavender General Trading
Metafor Lojistik
Naina Exporters and Importers
Piricas Trading Company
Rising Sun FZE
Sea Prince Logistics LLC
Seven Star Company
Shanghai Institute of Applied Physics, Chinese Academy of Sciences
Sun Yat-Sen University
Universal Logistics Systems GmbH
VIP Technology Ltd.
Xiang Cheng Gao Trading (HK) Ltd
Friday, 30 October 2020 at 12:41 EST | BIS Unverified List
40 entries removed (43 aliases)
Advent International Limited
Aisin Nantong Technical Center
AST Technology Group (HK) Ltd.
Beijing Institute of Nanoenergy and Nanosystems
Changchun Institute of Applied Chemistry, Chinese Academy of Sciences
Chepstow FZE
CITI Hong Kong Ltd
Foot Electronics Co. Ltd.
Fuiyen Technology Ltd.
GA Industry Co. Ltd.
Global Sourcing Electronics (HK) Ltd.
GS Technology Group Ltd.
GS Technology Ltd.
Hi-Shine Technology (HK) Limited
Hong Kong U.Star Electronics Technology Co. Ltd.
Hong Kong U.Star Electronics Technology Co., Ltd.
Hua Fu Technology Co. Ltd.
Institute of Geology, Chinese Academy of Geological Sciences
Microlink Communication Ltd.
Milectronic Communication Ltd.
Newplus Equipment Ltd.
Ningbo Zhongxian Optoelectronic Technology Co, Ltd.
People Tele-com Group
PetroChina International Jabung Ltd
Renmin University
Runtop Circuits Technology Co.
Shanghai Institute of Applied Physics Chinese Academy of Sciences
Shanghai Institute of Technical Physics Chinese Academy of Sciences
Shanghai SKEQI Automation Engineering Co.
Shi Jia Zhuang Suin Instruments, A-2 No. 99 Yuyuan Road, LuQuan District, Shijiazhuang, China 050000
Team Kingdom Limited
Termei Torch & Tip Company
Tianao Electronics Limited
Tongji University
Top-Rank Int Trade (HK)
Vessel Technology Limited
VIP Technology Ltd., Bechtereva Street 3/2, Office 40, Saint Petersburg, Russia
Win Electronics Limited
Win-Semi International Ltd
Xi'an Caijing Opto-Electronics Science and Technolgoy Co., Ltd
Xi'an Jiaotong University
Xi'an Micromach Photon Manufacture Technology
Yunnan Observatories, Chinese Academy of Sciences