Project 2025 Tracker / What’s done, what’s next

21. Department of Commerce · Notable

Add more Chinese and Russian entities to the Entity List with a denial policy

Partially done

Printed page 674 21. Department of Commerce

“Given China’s Civil–Military Fusion Strategy and Russia’s massive war efforts facilitated by a broad range of the Russian economy, BIS must add more entities to the Entity List and apply a license review “policy of denial” that prohibits exports to these entities.”

What has happened

  1. Partially done

    Twenty-nine more entries added, nineteen under China. The Chinese half of the ask has been delivered repeatedly; the Russian half has not — no rule in the window adds a Russian entity to the Entity List, and BIS removed a Chinese entity and six aliases on 2025-11-12 and two Arrow Electronics addresses on 2026-08-24. BIS also suspended for a year, on 2025-11-12, the interim final rule that would have extended Entity List restrictions to 50-per-cent-owned affiliates.

  2. Partially done

    Thirty-two more entities added, twenty-three under China; the same rule corrected twenty-seven existing entries including nine under Russia and three under Belarus, but added no new Russian entity.

  3. Partially done

    BIS added seventy entities to the Entity List, forty-two of them under China, on the finding that they act contrary to U.S. national security or foreign policy interests — Entity List entries carry a license review policy of denial, which is the second half of the Quote.

Research log

What was searched, and what didn’t count as evidence

Research notes

§3b’s two-object rule: the Quote names Chinese and Russian entities, and one object was delivered. Three rules added at least 84 Chinese entries; every one of them carries the license review policy of denial the Quote asks for, which was verified in each rule’s abstract. No in-window rule adds a Russian entity — the Russian entries touched in 2025-09-16 are typographical corrections, and the 2025-09-16 rule also removed two addresses from a Russian entry.

The other half of the picture, recorded in the last event’s note: BIS’s one structural expansion of Entity List reach — the 50-per-cent affiliates interim final rule of 2025-09-30 — was suspended on 2025-11-12 until 2026-11-09, and entries were removed on 2025-11-12 and 2026-08-24.

This is the same Entity List series that #1866 (Add TikTok and WeChat providers to the Entity List, major, not started) searched and found nothing in: adding many Chinese entities is not adding the two the other Quote names.

Action
expand
Object
Department of Commerce Entity List
ID
1863