A Deep Dive Into MEU, MIEU and CCMC Rules: Unpacking New Enforcement Risks, and the Hidden Lessons for Updating Export Compliance and Licensing Practices

Kay Georgi speaks at ACI's US-China Trade Controls Conference
  • Date & Time
    October 11, 2022 9:00 AM - 12:30 PM
  • Location Arlington, VA
  • Event Type
  • Add to Calendar Disabled
The Bureau of Industry and Security has imposed strict controls pertaining to “Communist Chinese Military Companies” (CCMCs); Chinese “Military End Users” (MEUs); and Chinese “Military-Intelligence End Users” (MIEUs). It has also been adding Chinese companies to the BIS Entity List based on concerns regarding the companies’ relationships to the Chinese military industrial complex. Those that do business in China and with Chinese companies need to understand these rules and revise screening and other compliance program efforts to account for the changes.

During this in-depth workshop, take a deep dive into the intricacies of complex MEU, MIEU and
CCMC Rules, including:

Definition of Communist Chinese Military Companies (CCMCs) restrictions

  • U.S. persons are, with some exceptions, prohibited from purchasing or selling:

    • Publicly traded securities of CCMCs
    • Securities that are derivative of publicly traded securities of CCMCs
    • Securities that are designed to provide investment exposure to publicly traded securities
      of CCMCs
  • Identification of CCMCs as “1237 entities”
    • Owned or controlled by, or affiliated with, the People’s Liberation Army or a ministry of the
      government of the People’s Republic of China or that is owned or controlled by an entity
      affiliated with the defense industrial base of the People’s Republic of China
    • Engaged in providing commercial services, manufacturing, producing, or exporting
  • Chinese “Military End Users” (MEUs)
    • Summary of Prohibitions
      • BIS’ expanded MEU definition
    • Affected Entities
      • BIS EAR supplements
    • Government Guidance
      • BIS guidance about the MEU rule
  • Chinese “Military-Intelligence End Users” (MIEUs)
    • Summary of Prohibitions
      • Definition of “Support”
      • The possibility that BIS will create a new MIEU list
    • Affected Entities
      • Definition of an MIEU
      • China’s identified examples
    • Summary of BIS’s Request for Comments
  • Gaining a better understanding of the extremely broad definition of the MIEU
  • Understanding the distinctions between and among the various lists in order to properly navigate compliance requirements
    • Examples of the many differences among CCMC, MEU, MIEU, and Entity List controls
  • Monitoring for further modifications to the MEU/MIEU measures as well as other pending
    regulatory actions


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