Entity List

Based on Wikipedia: Entity List

In September 2020, Huawei was racing against a deadline. Engineers and procurement teams across the Chinese tech giant worked frantically to stockpile chips—processors for 5G networks, WiFi components, display drivers, anything they could get their hands on. They bought from Samsung in South Korea, TSMC in Taiwan, MediaTek, and a constellation of other suppliers. The goal was simple: hoard enough components to keep the company running for at least two years.

Why the desperation? Because Huawei had been placed on something called the Entity List.

The Blacklist You've Never Heard Of

The Entity List sounds bureaucratic because it is. Published by the Bureau of Industry and Security (a division of the U.S. Department of Commerce that most Americans have never heard of), it's essentially a trade blacklist. Companies and organizations that end up on this list face severe restrictions on what American technology they can buy.

But here's what makes it interesting: the restrictions don't just apply to American companies selling directly to listed entities. They apply to any product containing significant American technology, no matter who makes it or where. That Taiwanese chip fabricated using American semiconductor equipment? Restricted. That German machine tool with American-designed software? Potentially restricted. The reach extends far beyond U.S. borders.

Think of it as a graduated punishment system. At the mildest level, you might end up on something called the Unverified List—basically a warning shot across the bow. The Entity List is more serious: you need a special license to receive controlled American technology, and those licenses are often denied. At the harshest extreme, you become a "denied person," essentially cut off entirely from American commerce.

From Weapons to Widgets

The Entity List was born in 1997 with a narrow purpose: tracking organizations that helped spread weapons of mass destruction. Nuclear materials. Chemical weapons precursors. The stuff of nonproliferation treaties and spy novels.

For its first decade, the list stayed relatively obscure. About two hundred entities, mostly aerospace companies, chemical suppliers, and logistics firms. The kind of thing export control lawyers worried about and everyone else ignored.

Then something changed.

Starting around 2008, the U.S. government began using the Entity List for broader purposes. National security concerns that went beyond weapons proliferation. Foreign policy objectives. Trade disputes dressed up in security language. By early 2017, the list had grown to roughly seven hundred entities. By late 2020, it had nearly doubled again to almost fourteen hundred.

Today, the list includes organizations from an unlikely mix of countries: China and Canada, Iran and Ireland, Russia and Switzerland, North Korea and the Netherlands. The through-line isn't geography—it's whatever the U.S. government has decided threatens American interests.

The Huawei Moment

May 2019 marked a turning point. That's when Huawei, the Chinese telecommunications giant, landed on the Entity List. This wasn't some obscure chemical supplier. Huawei was one of the world's largest smartphone manufacturers and the leading provider of 5G network equipment globally.

The official justification cited national security concerns—fears that Huawei equipment could be used for Chinese government espionage, though the company has consistently denied this. The practical effect was immediate and severe.

Huawei's smartphones had relied on Google's Android operating system and the suite of apps that make Android phones useful outside China: Gmail, Google Maps, the Play Store. Suddenly, new Huawei phones couldn't include any of this. Inside China, where Google services are already blocked, customers didn't notice. But in Europe, Africa, Southeast Asia—markets where Huawei had been gaining ground—the company's phones became dramatically less attractive.

Market share collapsed.

A year later, in May 2020, the restrictions tightened further. The U.S. government clarified that even chips designed by Huawei but manufactured by foreign companies using American equipment required licenses. This is what triggered that frantic stockpiling. Huawei had seen the writing on the wall—the daughter of its founder, Meng Wanzhou, had been arrested in Canada at U.S. request back in 2018—and had been building chip reserves since then.

Beyond China: A Growing Web

While Chinese companies dominate the Entity List—roughly 715 organizations as of mid-2024—the net has spread much wider.

In November 2021, two Israeli companies made the list: NSO Group and Candiru. If you've followed technology news, you might recognize NSO Group as the maker of Pegasus, the sophisticated spyware that has been used to hack the phones of journalists, activists, and political dissidents around the world. The U.S. government determined that these companies had supplied surveillance tools to foreign governments who used them to target "government officials, journalists, businesspeople, activists, academics, and embassy workers."

Note the irony: allied nations' companies, added to a list originally designed for weapons proliferators, because their software was being used against the very people democracies claim to protect.

Russia has earned its share of listings too. In August 2020, five Russian government facilities were added for work on chemical and biological weapons programs. In March 2021, the Biden administration listed fourteen more entities across Russia, Switzerland, and Germany for similar reasons.

Myanmar's military coup in 2021 brought a new round of listings. The message was clear: the Entity List had become a general-purpose foreign policy tool, not just a nonproliferation mechanism.

China Hits Back

The Chinese government, unsurprisingly, was not pleased to watch its technology sector targeted. In May 2019, the same month Huawei was listed, Beijing announced it would create its own "Unreliable Entities List."

The concept mirrors the American version but with Chinese characteristics. The list would target foreign companies that "endanger China's national sovereignty, security, or development interests" or engage in practices like "discriminating against a Chinese entity in violation of normal market transaction principles." That last phrase is particularly flexible—it could theoretically cover any company that complies with U.S. export controls.

For more than a year, the threat hung in the air without materialization. Then, in late 2020, after the Trump administration tried to ban TikTok and WeChat from American app stores, China finalized its regulations.

The first actual listings didn't come until 2023, when Lockheed Martin and Raytheon—two of America's largest defense contractors—were added. The symbolism was unmistakable: if you're going to target our tech companies, we'll target yours.

Then came a more surprising addition. In February 2025, PVH Corporation—the company behind Calvin Klein and Tommy Hilfiger—landed on China's list. The apparent reason? PVH had been under investigation for allegedly boycotting cotton from Xinjiang, the region where China has been accused of human rights abuses against Uyghur Muslims. By refusing to buy Xinjiang cotton (as many Western companies have done under pressure from human rights advocates), PVH had made itself a target.

The Subsidiary Problem

For years, the Entity List had an obvious loophole. If a Chinese company was listed, its overseas subsidiaries often weren't. Shell companies and corporate restructuring offered potential workarounds.

In September 2025, the Trump administration moved to close this gap. A new rule expanded Entity List coverage to include majority-owned subsidiaries—any company where a listed entity owns fifty percent or more. The implications rippled through global supply chains. Suddenly, a company with a Singapore address might fall under the same restrictions as its Beijing parent.

This was part of a broader evolution in how the U.S. government thinks about technology competition. It's no longer enough to restrict direct sales to concerning companies. The goal now is to restrict access across entire corporate networks.

What Gets Listed—And Why It Matters

The Chinese entities on the Entity List paint a picture of what Washington considers threatening. Huawei and its 5G equipment, obviously. But also research universities like Harbin Institute of Technology, one of China's premier engineering schools. Artificial intelligence companies. Surveillance equipment manufacturers—particularly those allegedly involved in monitoring Xinjiang. Companies that helped the Chinese military construct artificial islands in the South China Sea.

The concept underlying many of these listings is "military-civil fusion," a Chinese government strategy to ensure that civilian technology advances can be leveraged for military purposes. American officials argue that in China, unlike in the West, there's no clean separation between commercial tech companies and the military establishment.

Critics of the Entity List counter that the same could be said of American defense contractors, that the list has become a tool for economic protectionism dressed up as national security, and that cutting China off from advanced technology may backfire by spurring domestic Chinese innovation.

Both arguments contain truth. The Entity List is simultaneously a genuine security measure and a weapon in an economic competition. These aren't contradictions—they're features of the modern geopolitical landscape.

Living Under the List

For companies on the Entity List, life becomes considerably more complicated. Every supplier relationship has to be scrutinized for American content. Alternative sources must be developed, often at higher cost or lower quality. Research collaborations with American universities dry up. Talent recruitment becomes harder when employees fear being tainted by association.

Huawei's stockpiling strategy bought time, but time runs out. Chips become obsolete. Components wear out. The company has poured resources into developing its own semiconductor capabilities, but replicating decades of American and Taiwanese chip manufacturing expertise is a long road.

Meanwhile, the list keeps growing. What started as a narrow nonproliferation tool has become a central instrument of American technology policy. Whether that policy ultimately succeeds—whether it slows Chinese technological advancement or merely accelerates the bifurcation of the global technology system into American and Chinese spheres—remains to be seen.

What's certain is that a bureaucratic document most people have never heard of, published as "Supplement 4 of Part 744 of the Code of Federal Regulations," now shapes the trajectory of some of the world's most important industries. Export control lawyers have become strategically important. Chip supply chains are being redesigned around regulatory restrictions. And companies around the world nervously check their customer lists, wondering if their next sale might land them in the crosshairs of a government agency that didn't even exist before 1987.

The Entity List, it turns out, is one of the most consequential documents you've never read.