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US Should Add to Entity List, Prioritize Unilateral Controls, China Tech Threat Says

The Commerce Department should add more Chinese companies to the Entity List, better restrict China’s government organizations and target the country with unilateral controls when appropriate, China Tech Threat said this week. The organization, which is run by Strand Consult and advocates for stronger export controls on China, said Commerce should add China semiconductor companies Yangtze Memory Technologies and Changxin Memory Technologies to the Entity List and tailor export controls to better target Chinese “pseudo-government organizations.” Commerce should also “prioritize” unilateral controls on American semiconductor manufacturing equipment by employing a “control-now-cooperate-later” approach, China Tech Threat said.

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The Bureau of Industry and Security, which oversees export control efforts at Commerce, has said it constantly reviews whether to add more companies to the Entity List (see 2107130006). BIS officials also have said they prefer multilateral controls -- especially for items that also can be supplied by foreign countries -- but will use unilateral controls when necessary (see 2202100026 and 2201280045).