In a move underscoring the escalating scrutiny over the interplay between economic activities and national security concerns, the Department of Defense has significantly updated its list of Chinese Military Companies (CMCs) operating within the United States. This action, taken on Jan. 31, 2024, reflects the U.S. government’s ongoing efforts to identify entities contributing to the People’s Republic of China’s (PRC) Military-Civil Fusion strategy, which seeks to harness civilian enterprises in the service of its military advancement.
According to the DoD’s latest announcement, sixteen additional entities have been designated as CMCs under Section 1260H of the National Defense Authorization Act (the defense budget). This designation imposes certain restrictions on U.S. investments and raises the barrier for these companies in terms of accessing American markets and technologies. Conversely, three entities previously listed were removed after being determined to no longer meet the criteria for inclusion.
The DoD’s decision to update the CMC list is part of a broader strategy aimed at addressing the complex challenge posed by the PRC’s blending of its civilian and military sectors. By leveraging civilian innovation and resources, the Chinese government aims to enhance its military capabilities, raising concerns among U.S. policymakers about the potential for American investments to inadvertently bolster China’s military prowess.
The implications of these designations are significant for U.S. investors and companies, prompting a reevaluation of compliance strategies and investment portfolios to mitigate risks associated with the evolving regulatory landscape. Legal and trade experts emphasize the importance of staying abreast of these developments, as the DoD has signaled its intent to continue refining the CMC list in response to changing dynamics and intelligence assessments.
This update represents a critical juncture in U.S.-China relations, highlighting the intricate interconnections between global trade, technology transfer, and national security. As the U.S. government sharpens its focus on Chinese entities with military ties, the international business community must navigate an increasingly complex regulatory environment, balancing economic interests with the imperatives of national security.
| Entities Identified as Chinese Military Companies Operating in the United States. Those in bold were added to the list in January. |
| 360 Security Technology Inc. (Qihoo 360) |
| Advanced Micro-Fabrication Equipment Inc. China (AMEC) |
| Aerospace CH UAV Co., Ltd (S-SEA) |
| Aviation Industry Corporation of China Ltd. (AVIC) |
| AVIC Aviation High-Technology Company Limited (AVIC Aviation Hi-Tech) |
| AVIC Heavy Machinery Company Limited (AVIC Heavy Machinery) |
| AVIC Jonhon Optronic Technology Co., Ltd. (AVIC Jonhon) |
| AVIC Shenyang Aircraft Company Limited (AVIC Shenyang) |
| AVIC Xi’an Aircraft Industry Group Company Ltd. (AVIC Xi’an) |
| Jiangxi Hongdu Aviation Industry Co., Ltd. (Hongdu Aviation) |
| Zhonghang Electronic Measuring Instruments Company Limited (ZEMIC) |
| Beijing Megvii Technology Co., Ltd. (Megvii) |
| Beijing Zhidao Chuangyu Information Technology Co., Ltd. (Knownsec) |
| BGI Genomics Co., Ltd. (BGI) |
| Chengdu JOUAV Automation Tech Co., Ltd. (JOUAV) |
| Chengdu M&S Electronics Technology Co., Ltd. (M&S Electronics) |
| China Aerospace Science and Industry Corporation Limited (CASIC) |
| Aerosun Corporation (Aerosun) |
| China Communications Construction Group (Limited) (CCCG) |
| China Communications Construction Company Limited (CCCC) |
| China Construction Technology Co., Ltd. (CCTC) |
| China Electronics Corporation (CEC) |
| China Electronics Technology Group Corporation (CETC) |
| Hangzhou Hikvision Digital Technology Co., Ltd. (Hikvision) |
| China General Nuclear Power Corporation (CGN) |
| China Mobile Communications Group Co., Ltd. (China Mobile Comm) |
| China Mobile Limited (China Mobile) |
| China National Chemical Corporation Ltd. (ChemChina) |
| China National Chemical Engineering Group Corporation (CNCEC) |
| China National Nuclear Corporation (CNNC) |
| China National Offshore Oil Corporation (CNOOC) |
| CNOOC Limited |
| China North Industries Group Corporation Limited (Norinco Group) |
| Inner Mongolia First Machinery Group Co., Ltd. (Inner Mongolia) |
| China Railway Construction Corporation Limited (CRCC) |
| China South Industries Group Corporation (CSGC) |
| Costar Group Co., Ltd. (Costar) |
| China SpaceSat Co., Ltd. (China SpaceSat) |
| China State Construction Engineering Corporation Limited (CSCEC) |
| China State Construction Group Co. |
| China State Shipbuilding Corporation Limited (CSSC) |
| China Marine Information Electronics Company Limited (China Marine Info Elec) |
| China Telecom Group Co., Ltd. (China Telecom) |
| China Telecom Corporation Limited |
| China Telecommunications Corporation |
| China Three Gorges Corporation (CTG) |
