"Entity List" Articles (7)

Washington Pushes Back on Apple Buying Chinese Memory: Section 5949 and the Supplier Fallout

In August 2026, Commerce Secretary Lutnick said the administration opposes Apple sourcing Chinese memory. Here are the Senate and House letters, where CXMT and YMTC actually sit in US regulation, and what Section 5949 and the pending FAR rule mean for component suppliers in Japan and elsewhere.

2026-08-15Ryuta Hamamoto

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Why the BIS '50% Rule' Is So Hard to Comply With: Finding China's Hidden Subsidiaries

Talking with export-control officers, there's one regulation whose name I've heard more than any other over the past year.

2026-07-11Ryuta Hamamoto

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Was the BIS 50% Rule Delayed? What Can Happen Between November 9 and January 10

In September 2026 the US and China announced that the arrangement containing the stay of the BIS 50% Rule (Affiliates Rule) would run to January 10, 2027. The Federal Register stay still ends November 9. Here is what the primary documents say, what can happen between November 9 and January 10, and what exporters should check now.

2026-06-04Ryuta Hamamoto

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What Is the BIS 50% Rule? Stay Deadline, Extension Deal, and Ownership Math

The BIS Affiliates Rule extends Entity List controls by ownership. The Federal Register stay still ends November 9, 2026; the US and China have announced an extension to January 10, 2027 that BIS has not yet published. How the 50% test works and how to prepare for either date.

2026-05-20Ryuta Hamamoto

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Complete Guide: Entity List vs. MEU List vs. SDN List — When Japanese Companies Get Caught by the U.S. Big Three Restricted-Party Lists

Both are U.S. restricted-party lists, but the agencies, the way restrictions attach, and the delisting procedures are different.

2026-05-20Ryuta Hamamoto

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Taiwan SHTC Entity List Explained | Huawei and SMIC Among 601 Additions; Cumulative List Tops 11,480

I wrote this for officers who know Japan’s FEFTA but not Taiwan’s system. Below I map SHTC structure, the Huawei/SMIC addition timeline, and five practical steps.

2026-05-20Ryuta Hamamoto

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Sanctions Lists Explained: OFAC SDN, BIS Entity List, and Japan's End User List (2026)

What is the SDN List and how do you search it? A practical guide to OFAC's SDN and non-SDN lists, the BIS Entity List, Japan's End User List, and EU, UK, and UN sanctions lists, with last-update dates as of October 2026.

2026-04-24Ryuta Hamamoto