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As 2020 comes to a close, the U.S. Department of Commerce, Bureau of Industry and Security (BIS) continues to implement new measures targeting countries of interest, among them Russia and China (which now, for export purposes, officially includes Hong Kong). Because these measures are effective now, companies will need to ensure that they have in place procedures to ensure compliance with these measures, including compliance with licensing and reporting requirements.
On December 22, 2020, BIS published a final rule adding 77 entities to the Entity List as a result of their having been determined by the U.S. government to have been engaging in or enabling activities contrary to U.S. national security and foreign policy interests. The changes took effect December 18, 2020. Among the entities added to the Entity List pursuant to the rule is Semiconductor Manufacturing International Corporation Incorporated (SMIC)