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On December 23, 2020, the US Department of Commerce's Bureau of Industry and Security ("BIS") issued a final rule creating a "Military End User List" ("MEU List") under the Export Administration Regulations ("EAR"). The final rule also adopted the "first tranche" of entities added to the MEU List, identifying more than 100 Chinese and Russian entities as "Military End Users" ("MEUs").
1 A BIS license is required for certain exports, reexports, and transfers when a party has knowledge that an MEU is a party to the transaction (e.g., as purchaser, intermediate consignee, ultimate consignee, or end user). In a separate action, BIS also removed Hong Kong as a separate destination under the EAR, largely subjecting Hong Kong to the same requirements and restrictions as China.