Unreliable Entity List

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The Unreliable Entity List (Chinese: 不可靠实体清单; pinyin: Bù Kěkào Shítǐ Qīngdān) is a Chinese government sanctions system announced by the Ministry of Commerce on 31 May 2019. Its specific provisions were officially released on 19 September 2020. The Ministry of Commerce stated that foreign enterprises, organizations or individuals that do not comply with market rules, violate the spirit of contracts, block or cut off supplies to Chinese enterprises for non-commercial purposes, and seriously damage the legitimate rights and interests of Chinese enterprises will be included in the list. Individuals and entities included in the list will be fined and restricted from traveling to China.

History

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On 31 May 2019, a spokesperson for the Ministry of Commerce stated that, in accordance with relevant laws and regulations, China will establish an “unreliable entity list” system. The spokesperson said that foreign companies, organizations or individuals that do not comply with market rules, violate the spirit of contracts, impose blockades or supply cuts on Chinese companies for non-commercial purposes, or seriously damage the legitimate rights and interests of Chinese companies would be included in the unreliable entity list.[1] On June 8, 2019, according to The New York Times, the National Development and Reform Commission held a meeting with American, British and South Korean technology companies such as Microsoft, Dell, Samsung and SK Hynix. Representatives from the Ministry of Commerce and the Ministry of Industry and Information Technology also attended. The New York Times quoted sources as saying that the Chinese government representatives clearly warned at the meeting that if any company wanted to withdraw its production lines from China, exceed the standard purpose of safe dispersal, or participate in the implementation of the United States government's sanctions on China, it could be included in the unreliable entity list and be punished.[2] On 19 September 2020, China officially released the "Regulations on the Unreliable Entities List". Foreign entities included in the unreliable entities list may be restricted or prohibited from engaging in import and export activities related to China, or from investing in China.[3]

Content

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The regulations of the Ministry of Commerce state that, in order to safeguard national sovereignty, security and development interests, maintain a fair and free international economic and trade order, and protect the legitimate rights and interests of Chinese enterprises, other organizations or individuals, the "Regulations on the Unreliable Entities List" are formulated in accordance with the Foreign Trade Law, the National Security Law and other relevant laws. The Ministry stated that China would establish a working mechanism with the participation of relevant departments of the central government to be responsible for the organization and implementation of the unreliable entities list system and to decide whether to investigate the behavior of relevant foreign entities. Foreign entities included in the unreliable entities list may, depending on the actual situation, decide to take one or more of the following measures:[3][4]

  1. Restricting or prohibiting it from engaging in import and export activities related to China;
  2. Restricting or prohibiting its investment in China;
  3. Restricting or prohibiting the entry of its relevant personnel, means of transport, etc.;
  4. Restrict or cancel the work permits, stay or residence qualifications of their relevant personnel in China;
  5. A fine of appropriate amount shall be imposed according to the severity of the circumstances;
  6. Other necessary measures.

Inclusion criteria

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According to a 2020 order issued by the Ministry of Commerce, the Chinese government will take into account the following factors when deciding whether to include an entity in the "Unreliable Entities List":[4][non-primary source needed]

  1. Does the entity's behavior stem from non-commercial purposes and violate market rules, the spirit of contracts, and internationally accepted trade and economic rules?
  2. Does this entity engage in any actions such as imposing blockades, supply disruptions, or other discriminatory measures against Chinese entities?
  3. Does the entity's behavior stem from non-commercial purposes and violate market rules, the spirit of contracts, and internationally accepted trade and economic rules?
  4. Does the entity's actions cause substantial damage to the legitimate rights and interests of Chinese enterprises, other organizations, or individuals?
  5. Does this entity pose a threat or harm to China's national sovereignty, security, or development interests?
  6. Other factors that to be considered.

List

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As of 9 October 2025, a total of 72 entities (all of which are from the United States) were included in the Unreliable Entities List, of which 55 were under sanctions. Except for two entities that were retaliated against by the second Trump administration for imposing tariffs on China, the rest were sanctioned for United States arms sales to Taiwan.

Date Country/Region Entity Restrictions Ref.
Travel restrictions[note 1] Trade restrictions[note 2] Investment restrictions[note 3]
16 February 2023 File:Flag of the United States (23px).png United States Lockheed Martin Corporation Yes Yes Yes [5]
Raytheon Missiles & Defense Yes Yes Yes
20 May 2024 General Atomics Aeronautical Systems Yes Yes Yes
General Dynamics Land Systems Yes Yes Yes
Boeing Defense, Space & Security Yes Yes Yes
2 January 2025 General Dynamics Information Technology Yes Yes Yes [6]
General Dynamics Mission Systems Yes Yes Yes
General Dynamics Ordnance and Tactical Systems Yes Yes Yes
Lockheed Martin Advanced Technology Laboratory Yes Yes Yes
Lockheed Martin Aeronautics Yes Yes Yes
Lockheed Martin Missiles and Fire Control Yes Yes Yes
Lockheed Martin Missile System Integration Laboratory Yes Yes Yes
Lockheed Martin Ventures Yes Yes Yes
Raytheon/Lockheed Martin Javelin Joint Venture Yes Yes Yes
Raytheon Missile Systems Yes Yes Yes
14 January 2025 Anduril Industries Yes Yes Yes [7]
Applied Technologies Group Yes Yes Yes
Axient Yes Yes Yes
Inter-Coastal Electronics Yes Yes Yes
IronMountain Solutions Yes Yes Yes
Maritime Tactical Systems Yes Yes Yes
System Studies & Simulation Yes Yes Yes
15 January 2025 Aevex Aerospace Yes Yes Yes [8]
LKD Aerospace Yes Yes Yes
Pacific Rim Defense Yes Yes Yes
Summit Technologies, Inc. Yes Yes Yes
4 February 2025 Illumina, Inc. Yes Yes Yes [9]
PVH Corp. Yes Yes Yes
4 March 2025[note 4] ACT1 Federal Yes Yes Yes [11]
Cubic Corporation Yes Yes Yes
Exovera Yes Yes Yes
Huntington Ingalls Industries Inc. Yes Yes Yes
Planate Management Group Yes Yes Yes
S3 AeroDefense Yes Yes Yes
Stick Rudder Enterprises LLC Yes Yes Yes
TCOM, Limited Partnership Yes Yes Yes
Teledyne Brown Engineering, Inc. Yes Yes Yes
TextOre Yes Yes Yes
4 April 2025[note 5] BRINC Drones, Inc. Yes Yes Yes [14]
Domo Tactical Communications Yes Yes Yes
Firestorm Labs, Inc. Yes Yes Yes
HavocAI Yes Yes Yes
Insitu, Inc. Yes Yes Yes
Kratos Unmanned Aerial Systems, Inc. Yes Yes Yes
Neros Technologies Yes Yes Yes
Rapid Flight LLC Yes Yes Yes
Red Six Solutions Yes Yes Yes
Skydio Inc. Yes Yes Yes
SYNEXXUS, Inc. Yes Yes Yes
9 April 2025[note 6] Cyberlux Corporation Yes Yes Yes [15]
Edge Autonomy Operations LLC Yes Yes Yes
Group W Yes Yes Yes
Hudson Technologies Co. Yes Yes Yes
Shield AI, Inc. Yes Yes Yes
Sierra Nevada Corporation Yes Yes Yes
25 September 2025 Aerkomm Inc. No Yes Yes [16]
Oceaneering International, Inc. No Yes Yes
Saronic Technologies, Inc. No Yes Yes
9 October 2025 AeroVironment, Inc. No Yes Yes [17]
Alliant Techsystems Operations LLC No Yes Yes
BAE Systems, Inc. No Yes Yes
Cubic Global Defense No Yes Yes
Dedrone by Axon No Yes Yes
DZYNE Technologies No Yes Yes
Elbit Systems of America, LLC No Yes Yes
Epirus, Inc. No Yes Yes
Exelis Inc. No Yes Yes
Halifax International Security Forum No Yes Yes
Recorded Future, Inc. No Yes Yes
TechInsights Inc.[note 7] No Yes Yes
Teledyne FLIR, LLC No Yes Yes
VSE Corporation No Yes Yes
14 October 2025 Hanwha Shipping LLC No Yes Yes [18]
Hanwha Philly Shipyard Inc. No Yes Yes
Hanwha Ocean USA International LLC No Yes Yes
Hanwha Shipping Holdings LLC No Yes Yes
HS USA Holdings Corp. No Yes Yes

Notes

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  1. ^ Listed companies' executives are prohibited from entering mainland China, Hong Kong, and Macau, and existing work or residency permits are cancelled
  2. ^ Listed companies are prohibited from engaging in import and export trade with mainland China, Hong Kong and Macau
  3. ^ Prohibits new investments by listed companies in mainland China, Hong Kong, and Macau
  4. ^ The sanctions are ceased since 10 November 2025.[10]
  5. ^ The sanctions are suspended since 14 May 2025 for 90 days,[12] and extended since 12 August 2025 for another 90 days,[13] and extended since 10 November 2025 for one year.[10]
  6. ^ The sanctions are suspended since 14 May 2025,[12] and ceased since 12 August 2025.[13]
  7. ^ Including the following subsidiaries: TechInsights Europe Limited, TechInsights Europe Sp zo.o, TechInsights Japan KK, TechInsights USA Inc, TechInsights Korea Co. Ltd., TechInsights Market Analysis Limited, SARL Strategy Analytics, Strategy Analytics GmbH Market Research and Management Consulting, SARI Strategy Analytics Private Limited

References

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