IV.US Xinjiang - related Act Entity List

The Bureau of Industry and Security (BIS) of the U.S.Department of Commerce is responsible for maintaining multiple export control lists,which cover restrictive measures against specific countries and regions such as China and Russia.As of November 30,2024,the export control restriction lists include the following categories:

Data Source: The United States Code of Federal Regulations,the International Trade Administration of the United States Department of Commerce.

These export control lists have implemented relatively strict restrictive measures on enterprises in specific countries and regions,especially strictly regulating transactions related to sensitive industries (such as military and high - tech).

V.Countermeasures for Foreign Trade Enterprises

The DPL (Denied Persons List) primarily lists entities that are prohibited from participating in export activities.As of November 30,2024,there were 543 entities on the denied list,a decrease of 16 compared to October.Among them,there were 17 entities in China (located in Beijing,Jiangsu,Guangdong,Hong Kong,and Shanghai).The entities on the denied list in Shanghai remain the same.QINGSHAN LI,and its address is:

• Address:ROOM201,NO106LANE24,CHENSHANRD,PUDONGDISTRICT,SHANGHAI,200126,CN.

ToFor enterprises,ensuring that business counterparts are not on the DPL list is one of the important steps in compliance.

The Bureau of Industry and Security (BIS) of the US Department of Commerce is responsible for maintaining multiple export control lists,covering restrictive measures against specific countries and regions such as China and Russia.As of November 30,2024,the export control restrictive lists include the following categories:

The Economic Sanctions List (SDN) of the US Department of the Treasury is another important list affecting international trade.Entities on the SDN list are subject to strict economic sanctions,and any trade with them may violate US laws.

As of November 30,2024,there were a total of on the SDN list.16,818 entitieson the SDN list,an increase of 195 compared with October.Among them,there were 780 Chinese entities(5 new additions),among which49 were in Shanghai.The newly added Chinese entities include personnel or companies related to Gazprombank and VTB Bank.

• NewSanctionedEntities:
  • GAZPROMBANKJOINTSTOCKCOMPANYBeijingRepresentativeOffice
  • GPBFinancialServicesHongKongLimited(HongKong)
  • ElenaFedkina(VTBShanghaiPublicRelationsManager)
  • IlyaLishenko(VTBShanghaiSeniorPublicRelationsManager)
  • RomanLogov(VTBShanghaiDeputyGeneralManager)

When conducting international trade,enterprises should pay attention to avoiding any dealings with enterprises or individuals on the SDN list to avoid being regarded as violating US sanctions.

Name

In November 2024,the United States added two new entities to the list of its Xinjiang-related legislation (the "Uyghur Forced Labor Prevention Act"),with the involved companies mainly engaged in the production of agricultural products,minerals,and textiles.Among the 29 newly added entities,there is a company located in Shanghai — Shanghai JUMP Machinery & Technology Co.Ltd.(Shanghai Jiapai Machinery Technology Co.Ltd.).

Analysis of Newly Added Enterprises on the Xinjiang - related Act List:

• MostofthenewlyaddedenterprisesarelocatedinXinjiang,involvingtheproductionofmineralssuchasgold,lithium,andaluminum,aswellastheprocessingandexportofagriculturalproductsandfood.
• Enterprisesneedtopayspecialattentiontowhethertheyhavecooperationorsupplychainrelationshipswithentitiesonthelist.BecauseUSimportersfacemandatorydue-diligencerequirements,andonceaconnectionwiththeseenterprisesisfound,itmayleadtotheseizureofgoods.

Total number

Facing this increasingly complex trade compliance environment,foreign - trade enterprises should take the following measures to ensure compliant operations and avoid risks:

• UnderstandandComplywithExportControlRegulationsForeign-tradeenterprisesmustunderstandvariousUSexportcontrollists,especiallywhenitcomestotheexportofhigh-techproducts,sensitiveregions(suchasXinjiang),andmilitaryitems,toensurethatnotransactionsoccurwithentitiesonthelist.
• StrengthenInternalComplianceManagementEstablishasoundcompliancesystemandsetupacompliancemanagementdepartmenttoensurethateverytransactioniscarriedoutwithinthelegalframework.EspeciallyforbusinesseswithpotentialconnectionstoentitiesinRussia,Iran,andXinjiang-relatedentities,enterprisesneedtoconductadditionaldue-diligence.
• UseThird-PartyToolsforScreeningInordertoeffectivelyidentifypotentialrisks,enterprisescanusethird-partycompliancescreeningtoolstoconductbackgroundchecksonpartnersandtheirmanagement.ThiscanensurethattheyarenotonsanctionlistssuchasDPLandSDN.
• MaintainContactwithIndustryAssociationsandLawyersForeign-traderegulationsandsanctionsareoftenupdated.Enterprisesshouldobtainthelatestpolicyupdatesinatimelymannerthroughindustryassociationsandlawyers,soastoadoptappropriateresponsestrategiesandavoidunconsciousviolations.
• ConsiderAlternativeMarketsForsomehigh-riskmarkets(suchasthoserelatedtoXinjiang,Russia,etc.),enterprisescanconsiderdevelopingalternativemarketstoreducetheriskoftradedisruptionscausedbypoliticalreasons.

VI.Conclusion

With the complication of the global trade environment,foreign - trade enterprises are facing increasing compliance challenges.The US sanctions on multiple countries and regions and the continuous adjustment of export control lists have a direct impact on enterprises export businesses.

In order to avoid violating compliance regulations,enterprises must always pay attention to changes in relevant laws and regulations,and respond to the changing trade environment by strengthening compliance management,using third - party screening tools,and seeking legal support.Maintaining compliance is not only a necessary measure to avoid legal risks but also a fundamental guarantee for the long - term development and stable operation of enterprises.