Importantly, BIS amended the EAR to add a new criterion for placing a party on the Entity List: a sustained lack of cooperation by the host government to schedule and facilitate the completion of an end-use check of an entity identified on the Unverified List.
The US government’s decision to exclude China’s chip company Nanchang O-Film Tech (O-Film) from its so-called entity list is a welcome move that serves as a reminder for Washington that any irresponsible sanctions aiming to disrupt Chinese supply chains will invariably backfire, experts said.