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Sudden Sanctions Imposed! The U.S. Government Adds 23 Chinese Entities Including Fudan Microelectronics to Its "Blacklist", Bringing the Total Number of Entities on the List to Over 1,000

9/13/2025 12:53:37 PM

On September 12 local time, the U.S. Department of Commerce's Bureau of Industry and Security (BIS) issued an announcement stating that it had revised the Export Administration Regulations (EAR), adding a total of 32 entities to the controlled entity list. These entities span multiple countries and regions, including China (23 entities), India (1 entity), Iran (1 entity), Singapore (1 entity), Turkey (3 entities), and the United Arab Emirates (UAE, 2 entities).

Among them, 23 Chinese entities were added to the Entity List by the U.S. Department of Commerce in this round, including domestically produced chip-listed companies such as Shanghai Fudan Microelectronics Group Co., Ltd. (Fudan Microelectronics, 688385.SH; Shanghai Fudan, 01385.HK), the Aerospace Information Research Institute of the Chinese Academy of Sciences, and Hualing Co., Ltd. (Sino Ic Technology, 430139.BJ). Thirteen of these entities are related to semiconductors and integrated circuits, three are from the biotechnology and life sciences sectors, and the others span fields such as aerospace remote sensing, quantum technology, timing systems, industrial/engineering software, and supply chain and logistics services.

BIS stated that these companies or institutions have engaged in activities "contrary to U.S. national security or foreign policy interests," including supporting China's advanced computing, integrated circuit manufacturing, and distribution sectors, as well as participating in fields such as biotechnology, engineering software development, and semiconductor manufacturing equipment procurement. They are also accused of posing risks related to circumventing export controls and transshipping items to sanctioned entities.

BIS emphasized that for all entities listed on the Entity List, any items subject to EAR require a license for export, and such licenses are subject to a "presumption of denial." Some companies were also marked with Footnote 4, indicating that their production items related to supercomputing and AI technologies are also subject to controls. In simple terms, these semiconductor companies will be cut off from supplies in the relevant overseas industrial chain.

It is reported that since 2018, the U.S. government has been attempting to strengthen export controls to restrict China's access to advanced AI and chip technologies, as well as its capability to produce advanced semiconductors.

During Donald Trump's first presidential term, the U.S. government initiated the expansion of export controls on semiconductor technology to China, primarily through the "Entity List" (EL) mechanism administered by the Bureau of Industry and Security (BIS) under the U.S. Department of Commerce. This approach targeted specific Chinese companies by adding them to the Entity List, thereby restricting their access to certain technologies. Entities placed on the list are required to obtain licenses for the export, reexport, or transfer of items listed on the Commerce Control List (CCL), which includes dual-use items (those with both commercial and military applications) as well as other controlled technologies.

In 2020, the Bureau of Industry and Security (BIS) expanded the Foreign-Produced Direct Product Rule (FDPR). During the Biden administration, BIS added more Chinese entities to the export control list and strengthened technology and regional controls on advanced chips and related semiconductor manufacturing equipment (SME), such as those utilizing extreme ultraviolet (EUV) and deep ultraviolet (DUV) lithography technologies. Additionally, the U.S. government reached negotiated agreements with Japan and the Netherlands to align export control measures.
In 2022, BIS enhanced controls on certain advanced logic chips, integrated circuits, and SME related to advanced computing. In 2023, BIS included Chinese entities involved in advanced computing and artificial intelligence (AI) on the export control list, closed certain loopholes related to NVIDIA chips designed for the Chinese market that fell below previous computational control thresholds, and added more detailed controls on SME. Furthermore, in 2023, President Biden issued an executive order restricting U.S. investments in China's advanced chips and certain AI sectors.
In 2024, BIS expanded the scope of controls to include SME for advanced packaging, high-bandwidth memory (HBM) chips, and dynamic random-access memory (DRAM), further limiting Chinese entities' access to semiconductor technology. Simultaneously, BIS introduced controls on "node-agnostic" tools (used for both traditional and advanced chip production) as well as DUV and multiple patterning technologies. Additionally, BIS added over 130 Chinese entities to the Entity List.
On January 15, 2025, BIS issued a global rule aimed at curbing the proliferation of artificial intelligence, designed to restrict China's access to advanced chips and AI computing capabilities. At the same time, BIS terminated licenses for front-end chip equipment and technologies and limited China's access to advanced U.S. AI models and data permissions.

During Donald Trump's second term as U.S. President, his administration significantly altered the approach to regulating AI and semiconductor exports, adopting a mixed strategy of both tightening and loosening controls on chip exports.

Tightening Measures
The U.S. Department of Commerce's Bureau of Industry and Security (BIS) added 42 Chinese entities to the "Entity List," strengthening restrictions on their access to U.S. technology. Additionally, NVIDIA was required to obtain a license to sell its H20 GPU in China, and EDA companies were informed that they would need licenses to continue operations in the Chinese market. The Trump administration also revoked the Biden-era "Artificial Intelligence Export Rule," which had been designed to limit the spread of advanced AI technologies.

Easing Measures
During U.S.-China tariff negotiations, BIS temporarily delayed certain export control actions targeting China. In a significant policy shift, the agency lifted license requirements for EDA companies and approved NVIDIA and AMD to sell AI chips to China, under the condition that the U.S. government would receive 15% of the proceeds from these sales.

Background on NVIDIA's H20 Chip
The H20 is a customized "downgraded" AI chip based on NVIDIA's previous-generation Hopper architecture, specifically designed for the Chinese market. In response to the Biden administration's export control compliance requirements, NVIDIA launched the H20 in the first quarter of 2024 as a reduced-performance alternative to its flagship AI accelerators. According to industry analyses, the H20 delivers approximately 20% of the computing performance of the H100. While its specifications lag significantly behind those of NVIDIA's latest Blackwell architecture chips, the H20 still outperforms most domestically produced AI chips in China. Its compatibility with NVIDIA's software ecosystem and lower AI development costs have made it highly attractive. Following the rapid rise and widespread adoption of DeepSeek, leading Chinese internet companies have been actively purchasing the H20 to accelerate AI application deployment.

Today, the U.S. Bureau of Industry and Security (BIS) has once again added multiple Chinese entities to its "Entity List," with the most notable being the publicly listed company Fudan Microelectronics Group (Fudan Microelectronics), along with several of its affiliated entities.

According to its official website, Fudan Microelectronics is a leading Chinese company specializing in the design, development, production (testing), and provision of system solutions for very large-scale integrated circuits. Established in July 1998, the company went public on the Hong Kong Stock Exchange in 2000 and transitioned to the main board in 2014, making it one of the earliest and first publicly listed integrated circuit design enterprises in China. In 2021, it was listed on the Shanghai Stock Exchange's STAR Market, forming a dual "A+H" share capital structure.

Currently, Fudan Microelectronics has developed product lines including security and identification chips, non-volatile memory, smart meter chips, FPGA chips, and integrated circuit testing services. Its products are sold in over 30 countries and regions and are widely used in various fields such as finance, social security, automotive electronics, urban public transportation, electronic certificates, mobile payments, anti-counterfeiting traceability, smartphones, security monitoring, industrial control, signal processing, and intelligent computing.

The Aerospace Information Research Institute (AIR) under the Chinese Academy of Sciences was established in 2018 through the integration of the Institute of Electronics, the Institute of Remote Sensing and Digital Earth, and the Academy of Opto-Electronics. It operates 31 national and academy-level key laboratories and research centers. As of May 2025, AIR employs over 4,500 staff, including six academicians from the Chinese Academy of Sciences and the Chinese Academy of Engineering. Leveraging the core competencies of its predecessor institutions, AIR focuses on national strategic needs and aims to achieve major scientific and technological breakthroughs, having established a comprehensive, high-level research framework in the field of aerospace information.

Other entities added to the list include Hualing Co., Ltd. (Sino Ic Technology, 430139.BJ), Gemsky Semiconductor Technology (Wuxi) Co., Ltd., and several others.

According to data from the U.S. Department of Commerce's Bureau of Industry and Security (BIS), from 2018 to 2023, 2,641 license applications involving Chinese entities reviewed by BIS and its interagency partners were approved, with a total value of approximately $335 billion, while 1,293 applications were denied, withdrawn, or put on hold, valued at $545 billion. During the same period, the number of license applications involving Chinese entities on the Entity List increased from 5 in 2018 to 1,751 in 2021, accounting for about 28% of all license applications related to China. From 2018 to 2023, approximately 33% of license applications involving Chinese entities were denied, withdrawn, or put on hold.

As of March 31, 2025, the U.S. Bureau of Industry and Security (BIS) Entity List contains a total of 3,351 entries. It is important to note that a single entity may be listed under multiple countries or regions, resulting in a higher number of entries than actual entities. Among these, entities headquartered in China account for 1,065 entries, representing nearly one-third of the total. Meanwhile, the U.S. Department of the Treasury's Specially Designated Nationals (SDN) list includes 17,712 entries, of which 890 are based in China.

In response to the U.S. government's recent regulatory actions, Chinese Foreign Ministry Spokesperson Guo Jiakun has repeatedly stated that the U.S. is abusing export control tools such as the Entity List, using "threats to U.S. national security" and "violations of U.S. foreign policy" as pretexts to impose illegal unilateral sanctions. He characterized these actions as typical hegemonic behavior that severely violates international law and fundamental norms of international relations, undermines the legitimate rights and interests of enterprises, and jeopardizes the security and stability of global industrial and supply chains. China firmly opposes and strongly condemns these measures.

Guo Jiakun emphasized that China urges the U.S. to stop broadening the concept of national security, cease politicizing, instrumentalizing, and weaponizing economic, trade, and technological issues, and end the unreasonable suppression of Chinese companies through the abuse of various sanctions lists. China will take necessary measures to resolutely safeguard the legitimate rights and interests of Chinese enterprises.