Denied Party Digest

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DOD List of Communist Chinese Military Companies Updated

We’ve previously reported on the Department of Defense list of “Communist Chinese military companies.”  Now the list is a big longer.


More than twenty years in the making, the public list was first released in the summer of 2020.  The list, 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.


A third list was released on December 4th on the Department of Defense website, adding the following entities:

  • China Construction Technology Co. Ltd. (CCTC)
  • China International Engineering Consulting Corp. (CIECC)
  • China National Offshore Oil Corp. (CNOOC)
  • Semiconductor Manufacturing International Corp. (SMIC)


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 listed companies 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.