Unreliable Entity List

Sanctions by the Chinese government From Wikipedia, the free encyclopedia

The Unreliable Entity List (Chinese: 不可靠实体清单; pinyin: Bù Kěkào Shítǐ Qīngdān) is a Chinese government sanctions system announced by the Ministry of Commerce on 31 May 2019. Its specific provisions were officially released on 19 September 2020. The Ministry of Commerce stated that foreign enterprises, organizations or individuals that do not comply with market rules, violate the spirit of contracts, block or cut off supplies to Chinese enterprises for non-commercial purposes, and seriously damage the legitimate rights and interests of Chinese enterprises will be included in the list. Individuals and entities included in the list will be fined and restricted from traveling to China.

History

On 31 May 2019, a spokesperson for the Ministry of Commerce stated that, in accordance with relevant laws and regulations, China will establish an “unreliable entity list” system. The spokesperson said that foreign companies, organizations or individuals that do not comply with market rules, violate the spirit of contracts, impose blockades or supply cuts on Chinese companies for non-commercial purposes, or seriously damage the legitimate rights and interests of Chinese companies would be included in the unreliable entity list.[1] On June 8, 2019, according to The New York Times, the National Development and Reform Commission held a meeting with American, British and South Korean technology companies such as Microsoft, Dell, Samsung and SK Hynix. Representatives from the Ministry of Commerce and the Ministry of Industry and Information Technology also attended. The New York Times quoted sources as saying that the Chinese government representatives clearly warned at the meeting that if any company wanted to withdraw its production lines from China, exceed the standard purpose of safe dispersal, or participate in the implementation of the United States government's sanctions on China, it could be included in the unreliable entity list and be punished.[2] On 19 September 2020, China officially released the "Regulations on the Unreliable Entities List". Foreign entities included in the unreliable entities list may be restricted or prohibited from engaging in import and export activities related to China, or from investing in China.[3]

Content

The regulations of the Ministry of Commerce state that, in order to safeguard national sovereignty, security and development interests, maintain a fair and free international economic and trade order, and protect the legitimate rights and interests of Chinese enterprises, other organizations or individuals, the "Regulations on the Unreliable Entities List" are formulated in accordance with the Foreign Trade Law, the National Security Law and other relevant laws. The Ministry stated that China would establish a working mechanism with the participation of relevant departments of the central government to be responsible for the organization and implementation of the unreliable entities list system and to decide whether to investigate the behavior of relevant foreign entities. Foreign entities included in the unreliable entities list may, depending on the actual situation, decide to take one or more of the following measures:[3][4]

  1. Restricting or prohibiting it from engaging in import and export activities related to China;
  2. Restricting or prohibiting its investment in China;
  3. Restricting or prohibiting the entry of its relevant personnel, means of transport, etc.;
  4. Restrict or cancel the work permits, stay or residence qualifications of their relevant personnel in China;
  5. A fine of appropriate amount shall be imposed according to the severity of the circumstances;
  6. Other necessary measures.

Inclusion criteria

According to a 2020 order issued by the Ministry of Commerce, the Chinese government will take into account the following factors when deciding whether to include an entity in the "Unreliable Entities List":[4][non-primary source needed]

  1. Does the entity's behavior stem from non-commercial purposes and violate market rules, the spirit of contracts, and internationally accepted trade and economic rules?
  2. Does this entity engage in any actions such as imposing blockades, supply disruptions, or other discriminatory measures against Chinese entities?
  3. Does the entity's behavior stem from non-commercial purposes and violate market rules, the spirit of contracts, and internationally accepted trade and economic rules?
  4. Does the entity's actions cause substantial damage to the legitimate rights and interests of Chinese enterprises, other organizations, or individuals?
  5. Does this entity pose a threat or harm to China's national sovereignty, security, or development interests?
  6. Other factors that to be considered.

List

As of 9 October 2025, a total of 72 entities (all of which are from the United States) were included in the Unreliable Entities List, of which 55 were under sanctions. Except for two entities that were retaliated against by the second Trump administration for imposing tariffs on China, the rest were sanctioned for United States arms sales to Taiwan.

More information Date, Country/Region ...
DateCountry/RegionEntityRestrictionsRef.
Travel restrictions[note 1]Trade restrictions[note 2]Investment restrictions[note 3]
16 February 2023 United StatesLockheed Martin CorporationYesYesYes[5]
Raytheon Missiles & DefenseYesYesYes
20 May 2024General Atomics Aeronautical SystemsYesYesYes
General Dynamics Land SystemsYesYesYes
Boeing Defense, Space & SecurityYesYesYes
2 January 2025General Dynamics Information TechnologyYesYesYes[6]
General Dynamics Mission SystemsYesYesYes
General Dynamics Ordnance and Tactical SystemsYesYesYes
Lockheed Martin Advanced Technology LaboratoryYesYesYes
Lockheed Martin AeronauticsYesYesYes
Lockheed Martin Missiles and Fire ControlYesYesYes
Lockheed Martin Missile System Integration LaboratoryYesYesYes
Lockheed Martin VenturesYesYesYes
Raytheon/Lockheed Martin Javelin Joint VentureYesYesYes
Raytheon Missile SystemsYesYesYes
14 January 2025Anduril IndustriesYesYesYes[7]
Applied Technologies GroupYesYesYes
AxientYesYesYes
Inter-Coastal ElectronicsYesYesYes
IronMountain SolutionsYesYesYes
Maritime Tactical SystemsYesYesYes
System Studies & SimulationYesYesYes
15 January 2025Aevex AerospaceYesYesYes[8]
LKD AerospaceYesYesYes
Pacific Rim DefenseYesYesYes
Summit Technologies, Inc.YesYesYes
4 February 2025 Illumina, Inc.YesYesYes [9]
PVH Corp.YesYesYes
4 March 2025[note 4]ACT1 FederalYesYesYes[11]
Cubic CorporationYesYesYes
ExoveraYesYesYes
Huntington Ingalls Industries Inc.YesYesYes
Planate Management GroupYesYesYes
S3 AeroDefenseYesYesYes
Stick Rudder Enterprises LLCYesYesYes
TCOM, Limited PartnershipYesYesYes
Teledyne Brown Engineering, Inc.YesYesYes
TextOreYesYesYes
4 April 2025[note 5]BRINC Drones, Inc.YesYesYes[14]
Domo Tactical CommunicationsYesYesYes
Firestorm Labs, Inc.YesYesYes
HavocAIYesYesYes
Insitu, Inc.YesYesYes
Kratos Unmanned Aerial Systems, Inc.YesYesYes
Neros TechnologiesYesYesYes
Rapid Flight LLCYesYesYes
Red Six SolutionsYesYesYes
Skydio Inc.YesYesYes
SYNEXXUS, Inc.YesYesYes
9 April 2025[note 6]Cyberlux CorporationYesYesYes[15]
Edge Autonomy Operations LLCYesYesYes
Group WYesYesYes
Hudson Technologies Co.YesYesYes
Shield AI, Inc.YesYesYes
Sierra Nevada CorporationYesYesYes
25 September 2025Aerkomm Inc.NoYesYes[16]
Oceaneering International, Inc.NoYesYes
Saronic Technologies, Inc.NoYesYes
9 October 2025AeroVironment, Inc.NoYesYes[17]
Alliant Techsystems Operations LLCNoYesYes
BAE Systems, Inc.NoYesYes
Cubic Global DefenseNoYesYes
Dedrone by AxonNoYesYes
DZYNE TechnologiesNoYesYes
Elbit Systems of America, LLCNoYesYes
Epirus, Inc.NoYesYes
Exelis Inc.NoYesYes
Halifax International Security ForumNoYesYes
Recorded Future, Inc.NoYesYes
TechInsights Inc.[note 7]NoYesYes
Teledyne FLIR, LLCNoYesYes
VSE CorporationNoYesYes
14 October 2025 Hanwha Shipping LLCNoYesYes[18]
Hanwha Philly Shipyard Inc.NoYesYes
Hanwha Ocean USA International LLCNoYesYes
Hanwha Shipping Holdings LLCNoYesYes
HS USA Holdings Corp.NoYesYes
Close

Notes

  1. [1]
    Listed companies' executives are prohibited from entering mainland China, Hong Kong, and Macau, and existing work or residency permits are cancelled
  2. [2]
    Listed companies are prohibited from engaging in import and export trade with mainland China, Hong Kong and Macau
  3. [3]
    Prohibits new investments by listed companies in mainland China, Hong Kong, and Macau
  4. [4]
    The sanctions are ceased since 10 November 2025.[10]
  5. [5]
    The sanctions are suspended since 14 May 2025 for 90 days,[12] and extended since 12 August 2025 for another 90 days,[13] and extended since 10 November 2025 for one year.[10]
  6. [6]
    The sanctions are suspended since 14 May 2025,[12] and ceased since 12 August 2025.[13]
  7. [7]
    Including the following subsidiaries: TechInsights Europe Limited, TechInsights Europe Sp zo.o, TechInsights Japan KK, TechInsights USA Inc, TechInsights Korea Co. Ltd., TechInsights Market Analysis Limited, SARL Strategy Analytics, Strategy Analytics GmbH Market Research and Management Consulting, SARI Strategy Analytics Private Limited

References

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