IV. US Xinjiang - related Act Entity List

China

Shanghai	Entity List	China	Shanghai
Entity List	3081	838	77
Unverified End - User List	170	100	1
Final Military End - User List	57	57	6
Export Control Denied Persons List (DPL)	543	17	1
Total	3854	1012	85

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) mainly lists the entities prohibited from participating in export activities. As of November 30, 2024, there were 543 entities on the Denied Persons List, a decrease of 16 compared with October. Among them, there were 17 entities in China (distributed in Beijing, Jiangsu, Guangdong, Hong Kong, and Shanghai). The entity in Shanghai is stillQINGSHAN LI, and its address is:

• Address: ROOM 201, NO106 LANE 24, CHENSHAN RD, PUDONG DISTRICT, SHANGHAI, 200126, CN.

Yesforeign tradeFor 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 were16,818 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.

• New Sanctioned Entities:
  • GAZPROMBANK JOINT STOCK COMPANY Beijing Representative Office
  • GPB Financial Services Hong Kong Limited(Hong Kong)
  • Elena Fedkina(VTB Shanghai Public Relations Manager)
  • Ilya Lishenko(VTB Shanghai Senior Public Relations Manager)
  • Roman Logov(VTB Shanghai Deputy General Manager)

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 US Xinjiang - related Act (i.e., the Uyghur Forced Labor Prevention Act) list added two batches of entities. The enterprises involved are 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:

• Most of the newly added enterprises are located in Xinjiang, involving the production of minerals such as gold, lithium, and aluminum, as well as the processing and export of agricultural products and food.
• Enterprises need to pay special attention to whether they have cooperation or supply chain relationships with entities on the list. Because US importers face mandatory due - diligence requirements, and once a connection with these enterprises is found, it may lead to the seizure of goods.

Total number

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

1. Understand and Comply with Export Control Regulations Foreign - trade enterprises must understand various US export control lists, especially when it comes to the export of high - tech products, sensitive regions (such as Xinjiang), and military items, to ensure that no transactions occur with entities on the list.
2. Strengthen Internal Compliance Management Establish a sound compliance system and set up a compliance management department to ensure that every transaction is carried out within the legal framework. Especially for businesses with potential connections to entities in Russia, Iran, and Xinjiang - related entities, enterprises need to conduct additional due - diligence.
3. Use Third - Party Tools for Screening In order to effectively identify potential risks, enterprises can use third - party compliance screening tools to conduct background checks on partners and their management. This can ensure that they are not on sanction lists such as DPL and SDN.
4. Maintain Contact with Industry Associations and Lawyers Foreign - trade regulations and sanctions are often updated. Enterprises should obtain the latest policy updates in a timely manner through industry associations and lawyers, so as to adopt appropriate response strategies and avoid unconscious violations.
5. Consider Alternative Markets For some high - risk markets (such as those related to Xinjiang, Russia, etc.), enterprises can consider developing alternative markets to reduce the risk of trade disruptions caused by political reasons.

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.