Trading with the Entity: Impact on Non-US Manufacturers from Huawei’s Addition to the Entity List
The U.S. Commerce Department, Bureau of Industry and Security (“BIS”) published a final rule on May 21, 2019, adding the largest telecommunications-equipment manufacturer in the world, Huawei Technologies Co., Ltd., and 68 of its non-US affiliates (collectively, “Huawei”), to BIS’s Entity List. See 84 FR 22961. This rule imposes an export license requirement for all…