Denied Party Digest

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Know Your Sanctions Lists (Beyond the CSL) – Communist Chinese Military Companies

Beyond the Consolidated Screening List, ECScreening provides data from a growing number of official U.S. and foreign government sanctions lists and other sources to bring useful information to subscribers. 

One of these lists, more than twenty years in the making, was first released in the summer of 2020.  The list of “Communist Chinese military companies,” required by section 1237 of the National Defense Authorization Act for FY 1999, was first released in a letter to Senator Tom Cotton on June 24th.  A second list was released on a Department of Defense website on August 28th.

The June list included the following entities:

  • Aviation Industry Corporation of China (AVIC)
  • China Aerospace Science and Technology Corporation (CASC)
  • China Aerospace Science and Industry Corporation (CASIC)
  • China Electronics Technology Group Corporation (CETC)
  • China South Industries Group Corporation (CSGC)
  • China Shipbuilding Industry Corporation (CSIC)
  • China State Shipbuilding Corporation (CSSC)
  • China North Industries Group Corporation (Norinco Group)
  • Hangzhou Hikvision Digital Technology Co., Ltd. (Hikvision)
  • Huawei
  • Inspur Group
  • Aero Engine Corporation of China
  • China Railway Construction Corporation (CRCC)
  • CRRC Corp.
  • Panda Electronics Group
  • Dawning Information Industry Co (Sugon)
  • China Mobile Communications Group
  • China General Nuclear Power Corp.
  • China National Nuclear Corp.
  • China Telecommunications Corp.

The August release added the following entities:

  • China Communications Construction Company (CCCC)
  • China Academy of Launch Vehicle Technology (CALT)
  • China Spacesat
  • China United Network Communications Group Co Ltd
  • China Electronics Corporation (CEC)
  • China National Chemical Engineering Group Co., Ltd. (CNCEC)
  • China National Chemical Corporation (ChemChina)
  • Sinochem Group Co Ltd
  • China State Construction Group Co., Ltd.
  • China Three Gorges Corporation Limited
  • China Nuclear Engineering & Construction Corporation (CNECC)

The list does not immediately affect export controls.  The listed companies, however, could potentially be the subject of future sanctions and inclusion on the list should be considered a “red flag” under the expanded restrictions on Chinese military end-users.  Some companies, such as Huawei, are already sanctioned under other authorities.