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Rounding out an already-intense 2020, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued three notices in December that expanded export sanctions and restrictions against Chinese, Russian, and other enterprises and institutions accused of engaging in activities contrary to U.S. interests. On December 18, BIS announced export sanctions against Semiconductor Manufacturing International Corporation (“SMIC”), the largest semiconductor producer in the People’s Republic of China (“PRC”), along with 76 other entities, the vast majority of which are PRC enterprises and research institutes. On December 23, BIS created a new Military End User (“MEU”) List that designates specific PRC and Russian entities for more stringent export licensing requirements under the MEU rule expanded by BIS earlier in the year. Finally, also on December 23, BIS officially terminated Hong Kong’s status as a jurisdiction separate from the PRC under the U.S. Export Administration Regulations (“EAR”), meaning that U.S. exports to Hong Kong will now be treated as if they are exports to the PRC itself.