I. Categories and Total Numbers of Export Control Lists of the US Department of Commerce

As of October 31, 2024, there were a total of 3,870 entities on the export control restrictive lists maintained by the Bureau of Industry and Security (BIS) of the US Department of Commerce, of which 1,012 were in China, accounting for 26.1% of the total.

• Entity List: A total of 3,081 entities, of which 838 were in China.
• Unverified End - User List: A total of 170 entities, of which 100 were in China.
• Final Military End - User List: A total of 57 entities, all of which were Chinese enterprises.
• Export Control Denied Persons List (DPL): A total of 559 entities, of which 17 were in China.

Total: A total of 3,870 entities, of which 1,012 were in China.

Data Sources: US Federal Regulations Library, International Trade Administration of the US Department of Commerce.

II. Export Control Entity List

(I) Total Number

The total number of entries on the Entity List is 3,081, an increase of 65 compared to September, and the number of entities involved is 3,040. Since one entity may be listed in multiple countries or regions, the number of entries will be greater than the number of entities.

The top five countries and regions in terms of the number of Entity List entries are:

• Russia: 1,079 entity entries, accounting for 35% of the total.
• China: 838 entity entries, accounting for 27.2% of the total.
• United Arab Emirates: 182 entity entries, accounting for 5.9% of the total.
• Pakistan: 163 entity entries, accounting for 5.3% of the total.
• Iran: 112 entity entries, accounting for 3.6% of the total.

Data Source for the Number of Entities: International Trade Administration of the US Department of Commerce.

(II) Number of Chinese Entities Involved with Russia

Since the outbreak of the Russia - Ukraine war in 2022, a total of 150 Chinese (including Hong Kong) enterprises have been included in the Entity List by the US Department of Commerce due to their involvement with Russia. Among them, 1 batch of 5 were added in 2022, 5 batches of 67 were added in 2023, 78 were added in 2024, and 11 were added in October.

(III) Chinese Enterprises in the New Russia - related Entity List Added on October 30, 2024 (11 in total)

1. Analog Technology Limited, Hong Kong, Anologe Technology Co. Ltd.
2. Address 12, Room 1502, Easey Commercial Building, 253-261 Hennessy Road, Wan Chai, Hong Kong.
3. Address 13, Room 1005, 10/F, Ho King Commercial Center, 2-16 Fayuen St, Mong Kok, Kowloon, Hong Kong.
4. Address 14, Room B, 5/F Gaylord Commercial Building, 114-118 Lockhart Road, Wan Chai, Hong Kong.
5. Address 15, Flat 1512, 15/F, Lucky Centre, No. 165-171 Wan Chai Road, Wan Chai, Hong Kong.
6. Beijing Aerospace Hill Test Technology Co., Ltd., Beijing Aerospace Hill Test Technology Co., Ltd.
7. Shenzhen True Price Technology Co., Ltd., Shenzhen True Price Technology Co., Ltd
8. Suzhou Tiangong Mechanics Testing Technology Co., Ltd., Suzhou Tiangong Mechanics Testing Technology Co., Ltd.
9. Suzhou Tiangong Testing Technology Co., Ltd., Suzhou Tiangong Testing Technology Co., Ltd.
10. Woke Trading H.K. Limited, affiliated with Shenzhen Woke Commerce and Trade Co., Ltd., Shenzhen Walker Trade Co., Ltd.; Woke Trading Shenzhen Co., Ltd.; and Woke Trading Hongkong Limited.

(IV) Entities Involved in the Proliferation of Weapons of Mass Destruction Added on October 21, 2024 (6 in China)

1. Beijing Moreget Creative Technology Co., Ltd.
2. Detail Technology (НК) Limited, Hong Kong, Ditel Technology Co., Ltd. (dissolved).
3. L-Tong Electronic Technology Company, suspected of procuring controlled items from Iran.
4. Shenzhen Dragonfly Supply Chain Co., Ltd., Shenzhen Dragonfly Supply Chain Co., Ltd.
5. Shenzhen Jiachuang Weiye Technology Company, Ltd., Shenzhen Jiachuang Weiye Technology Co., Ltd.
6. Small Leopard Electronics Co., Limited, Hong Kong, Xiaobao Electronics Co., Ltd. (closed).

III. Export Control Unverified Users List

In October 2024, the US Department of Commerce added 8 export - controlled unverified users, of which 3 were in China, and removed 2 (1 of which was a Chinese entity). As of October 31, 2024, there were a total of 173 entities on the Unverified End - User List, of which 100 were in China (including Hong Kong).

• Newly added:
  1. Hengye Technology Co., Ltd., 1602 Dingcheng International Building, Zhonghang Road, Futian District, Shenzhen.
  2. Skytop Electronics Ltd., Hong Kong.
  3. YXS Technology Co., Ltd., Shenzhen Yanshengxing Technology Co., Ltd.
• Removed:
  1. Shengwei Technology Co., Ltd., Hong Kong.

IV. Total Number of Export Control End - Use Military Users

No change. As of October 31, 2024, there were 57 entities on the End - Use Military User List, all of which were Chinese enterprises. Since March 3, 2022, Russian end - use military users have been transferred to the management of the Entity List, marked with footnote 3. In addition, some Iranian and Chinese entities have been included in the Russian end - use military user list due to their involvement in Russias military activities, marked with footnote 3 in the Entity List. Currently, there are 6 Shanghai enterprises on this list, all of which were included on December 23, 2020.

V. Export Control Denied Persons List (DPL)

No change. As of October 31, 2024, there were 559 entities on the Denied Persons List, of which 17 had addresses in China (4 in Beijing, 2 in Jiangsu, 1 in Guangdong, 9 in Hong Kong, and 1 in Shanghai).

VI. Analysis of the US Department of the Treasurys Economic Sanctions List (SDN)

(I) Total Number in October

As of October 31, 2024, the US Department of the Treasurys Economic Sanctions List (SDN) had 16,623 entries, an increase of 511 compared to 16,132 in September. Among them, 775 had addresses in China, an increase of 63 compared to the previous month. There were 46 Shanghai entities on the SDN list, and 2 were added in October.

(II) New Chinese Entities and Individuals Added on October 30, 2024 (Involved with Russia)

54 new Chinese entities were added, including:

1. LIN, Qing (Shenzhen)
2. PENG, Minbo (Hong Kong)
3. 3K GROUP LIMITED (Hong Kong)
4. ABLEFAST LOGISTICS SHENZHEN LIMITED (Shenzhen)
5. ACE ELECTRONIC HK CO., LIMITED (Shenzhen, Hong Kong)
6. ACS SYSTEMS LIMITED (Hong Kong)
7. AFOX CORPORATION LIMITED (Hong Kong)
8. ALIGN TRADING CO., LIMITED (Hong Kong)
9. ALLPARTS TRADING CO., LTD (Hong Kong)
10. AUSPICIOUS SUN LIMITED (Hong Kong)
11. AVINEX GLOBAL LIMITED (Shenzhen)
12. AVTEX SEMICONDUCTOR LIMITED (Shenzhen)
13. BEIJING DYNAMIC POWER CO LIMITED (Beijing)
14. BEYOND CENTER LIMITED (Hong Kong)
15. BHOOMI HK LIMITED (Hong Kong)
16. CARGO LINKEDIN INTERNATIONAL LIMITED (Hong Kong)
17. CHIPGOO ELECTRONICS LIMITED (Hong Kong)
18. CHIPS RESOURCES LIMITED (Hong Kong)
19. CLF GLOBAL LIMITED (Hong Kong)
20. ELE TECHNOLOGY CO LTD (Shenzhen)
21. ETOP ELECTRONICS HK CO LIMITED (Hong Kong)
22. FK HK LIMITED (Hong Kong)
23. GOLDVAST ENTERPRISES COMPANY LIMITED (Hong Kong)
24. GRANTS PROMOTION SERVICE LIMITED (Hong Kong)
25. GROUP YEOH LIMITED (Hong Kong)
26. HK LINK ASIA ELECTRONICS LIMITED (Hong Kong)
27. HONESTWIN TECHNOLOGY CO LIMITED (Hong Kong)
28. HONG KONG QISU ELECTRONIC TECHNOLOGY CO LIMITED (Hong Kong)
29. Jiangsu Catofish General Electric Co Ltd (Jiangsu)
30. Jiaxing Yongchi Mechanical and Electrical Co Ltd (Jiaxing, Zhejiang)
31. Jove HK Limited (Hong Kong)
32. JST Group Limited (Hong Kong)
33. MAXTRONIC GLOBAL LIMITED (Shenzhen)
34. MEGACHIPS LIMITED (Hong Kong)
35. MIDAS LIGHTING LIMITED (Hong Kong)
36. MINHOO LOGISTICS LIMITED (Hong Kong)
37. MOROTACK TIANJIN TECHNOLOGY CO LTD (Tianjin)
38. NANCHANG KUDOS IMPORT AND EXPORT COMPANY LIMITED (Nanchang)
39. POLAR BEAR ELECTRONICS CO., LIMITED (Hong Kong)
40. RICHTERK HONGKONG ELECTRONIC CO LIMITED (Hong Kong)
41. ROFO TRADING CO LTD (Anhui)
42. SHANGHAI WINSUN IMP AND EXP CO LTD (Pudong, Shanghai)
43. SHANGHAI ZHANJIA TRADING CO LTD (Minhang, Shanghai)
44. SHANGYIYUAN RESOURCES QINGDAO CO LTD (Qingdao)
45. SHENZHEN A TECHNOLOGY CO LTD (Shenzhen)
46. SHENZHEN ONE WORLD INTERNATIONAL LOGISTICS CO LTD (Shenzhen)
47. SINNO GROUP LIMITED (Hong Kong)
48. SUNSHINE LOGISTICS SHENZHEN CO LTD (Shenzhen)
49. WIN KEY LIMITED (Hong Kong)
50. WUHAN HUAZHONG NUMERICAL CONTROL CO LTD (Wuhan)
51. XH SMART TECH CHINA CO LTD (Zhuhai)
52. YIWU VORTEX IMPORT AND EXPORT CO LIMITED (Hong Kong)
53. ZHEJIANG HEADMAN MACHINERY CO LTD (Taizhou)
54. ZHUHAI RAYSHARP TECHNOLOGY CO LTD (珠海)

(III) New Sanctioned Targets in Other Fields

Multiple new Chinese individuals and entities were added, involving the Houthi armed forces, Iranian oil transportation, Russian drone production, etc.

Summary

截至2024年10月，美國對外出口管制和制裁措施持續(xù)升級，特別是針對中國企業(yè)的監(jiān)管力度不斷加大。無論是實體清單的更新，還是經(jīng)濟制裁名單的擴展，這些措施都對外貿(mào)企業(yè)的合規(guī)提出了更高的要求。對于相關(guān)企業(yè)而言，密切關(guān)注政策動態(tài)、加強合規(guī)審查、尋求專業(yè)法律顧問的支持是確保業(yè)務(wù)持續(xù)合規(guī)的關(guān)鍵。