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, 香港，安諾格科技有限公司
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., 北京航天希爾測試技術(shù)有限公司
7. Shenzhen True Price Technology Co., Ltd., 深圳市真價科技有限公司
8. Suzhou Tiangong Mechanics Testing Technology Co., Ltd., 蘇州天工力學測試技術(shù)有限公司
9. Suzhou Tiangong Testing Technology Co., Ltd., 蘇州天工測試技術(shù)有限公司
10. Woke Trading H.K. Limited, 關(guān)聯(lián)，Shenzhen Woke Commerce and Trade Co., Ltd., 深圳市沃克商貿(mào)有限公司; Shenzhen Walker Trade Co., Ltd.; Woke Trading Shenzhen Co., Ltd.; 和 Woke Trading Hongkong Limited，沃克商貿(mào)香港有限公司。

(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., 北京摩詰創(chuàng)新科技股份有限公司。
2. Detail Technology (НК) Limited, Hong Kong, Ditel Technology Co., Ltd. (dissolved).
3. L-Tong Electronic Technology Company, 涉嫌向伊朗采購管制物項。
4. Shenzhen Dragonfly Supply Chain Co., Ltd., 深圳市蜻蜓供應鏈有限公司。
5. Shenzhen Jiachuang Weiye Technology Company, Ltd., 深圳市佳創(chuàng)偉業(yè)科技有限公司。
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., 深圳市福田區(qū)中航路鼎誠國際大廈1602。
  2. Skytop Electronics Ltd., 香港。
  3. YXS Technology Co., Ltd., 深圳市燕興盛科技有限公司。
• Removed:
  1. Shengwei Technology Co., Ltd., 香港。

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 (深圳)
2. PENG, Minbo (香港)
3. 3K GROUP LIMITED (香港)
4. ABLEFAST LOGISTICS SHENZHEN LIMITED (深圳)
5. ACE ELECTRONIC HK CO., LIMITED (深圳、香港)
6. ACS SYSTEMS LIMITED (香港)
7. AFOX CORPORATION LIMITED (香港)
8. ALIGN TRADING CO., LIMITED (香港)
9. ALLPARTS TRADING CO., LTD (香港)
10. AUSPICIOUS SUN LIMITED (香港)
11. AVINEX GLOBAL LIMITED (深圳)
12. AVTEX SEMICONDUCTOR LIMITED (深圳)
13. BEIJING DYNAMIC POWER CO LIMITED (北京)
14. BEYOND CENTER LIMITED (香港)
15. BHOOMI HK LIMITED (香港)
16. CARGO LINKEDIN INTERNATIONAL LIMITED (香港)
17. CHIPGOO ELECTRONICS LIMITED (香港)
18. CHIPS RESOURCES LIMITED (香港)
19. CLF GLOBAL LIMITED (香港)
20. ELE TECHNOLOGY CO LTD (深圳)
21. ETOP ELECTRONICS HK CO LIMITED (香港)
22. FK HK LIMITED (香港)
23. GOLDVAST ENTERPRISES COMPANY LIMITED (香港)
24. GRANTS PROMOTION SERVICE LIMITED (香港)
25. GROUP YEOH LIMITED (香港)
26. HK LINK ASIA ELECTRONICS LIMITED (香港)
27. HONESTWIN TECHNOLOGY CO LIMITED (香港)
28. HONG KONG QISU ELECTRONIC TECHNOLOGY CO LIMITED (香港)
29. JIANGSU CATOFISH GENERAL ELECTRIC CO LTD (江蘇)
30. JIAXING YONGCHI MECHANICAL AND ELECTRICAL CO LTD (浙江嘉興)
31. JOVE HK LIMITED (香港)
32. JST GROUP LIMITED (香港)
33. MAXTRONIC GLOBAL LIMITED (深圳)
34. MEGACHIPS LIMITED (香港)
35. MIDAS LIGHTING LIMITED (香港)
36. MINHOO LOGISTICS LIMITED (香港)
37. MOROTACK TIANJIN TECHNOLOGY CO LTD (天津)
38. NANCHANG KUDOS IMPORT AND EXPORT COMPANY LIMITED (南昌)
39. POLAR BEAR ELECTRONICS CO., LIMITED (香港)
40. RICHTEK HONGKONG ELECTRONIC CO LIMITED (香港)
41. ROFO TRADING CO LTD (安徽)
42. SHANGHAI WINSUN IMP AND EXP CO LTD (上海浦東)
43. SHANGHAI ZHANJIA TRADING CO LTD (上海閔行)
44. SHANGYIYUAN RESOURCES QINGDAO CO LTD (青島)
45. SHENZHEN A TECHNOLOGY CO LTD (深圳)
46. SHENZHEN ONE WORLD INTERNATIONAL LOGISTICS CO LTD (深圳)
47. SINNO GROUP LIMITED (香港)
48. SUNSHINE LOGISTICS SHENZHEN CO LTD (深圳)
49. WIN KEY LIMITED (香港)
50. WUHAN HUAZHONG NUMERICAL CONTROL CO LTD (武漢)
51. XH SMART TECH CHINA CO LTD (珠海)
52. YIWU VORTEX IMPORT AND EXPORT CO LIMITED (香港)
53. ZHEJIANG HEADMAN MACHINERY CO LTD (臺州)
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

As of October 2024, US foreign export control and sanction measures have continued to escalate, especially the regulatory efforts against Chinese enterprises have been continuously strengthened. Whether it is the update of the Entity List or the expansion of the economic sanctions list, these measures have put forward higher requirements for enterprises compliance. For relevant enterprises, closely monitoring policy dynamics, strengthening compliance reviews, and seeking the support of professional legal counsel are the keys to ensuring continuous business compliance.foreign tradeHigher requirements are put forward for the compliance of enterprises. For relevant enterprises, closely following policy dynamics, strengthening compliance review, and seeking the support of professional legal counsel are the keys to ensuring the continuous compliance of business.