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