2 active designations from the surveyed authorities. Each is a public government record with a different legal effect — read the type label and scope on each.
US BISExport controlEntity List (Xinjiang / human-rights tranche) · 2020-06-05
A license is required to export US-origin items/technology to the entity, typically reviewed under a presumption of denial (e.g. BIS Entity List). It is not an asset freeze.
Added to the BIS Entity List by final rule effective June 5, 2020 (announced May 22, 2020), listed at 15 CFR part 744 Supplement No. 4 under China. Listed as 'CloudWalk Technology' with four aliases (Chongqing Cloudwalk Technology Co., Ltd.; Guangzhou Yunshang Information Technology Co., Ltd.; Yun Cong Information Technology Co. Ltd.; Yun Cong Technology). Reason given: implicated in human-rights violations and abuses in the implementation of China's campaign of repression, mass arbitrary detention, forced labor, and high-technology surveillance against Uighurs, Kazakhs, and other members of Muslim minority groups in the Xinjiang Uighur Autonomous Region (XUAR). License requirement: license required for all items subject to the EAR, no license exceptions available; license review policy of case-by-case review for ECCNs 1A004.c, 1A004.d, 1A995, 1A999.a, 1D003, 2A983, 2D983, 2E983 and for EAR99 items, and presumption of denial for all other items subject to the EAR. SCOPE: this is an EXPORT-CONTROL restriction on the export, reexport, and transfer of US-origin items and technology to the entity; it is NOT a financial sanction or asset freeze and does not bar all dealings. Verified against the Federal Register final rule; no evidence of removal as of the research date. NOTE: an October 2019 listing hint is incorrect — CloudWalk was added in the May/June 2020 tranche, not the October 2019 tranche (which covered Hikvision, Dahua, Megvii, SenseTime, Yitu, iFlytek, and others).
Federal Register, Vol. 85, No. 109 (June 5, 2020) — Addition of Entities to the Entity List (final rule, 2020-10868)
US Treasury (OFAC)Investment restrictionNon-SDN Chinese Military-Industrial Complex Companies (NS-CMIC) List · 2021-12-16
US persons are barred from buying or selling the company’s publicly traded securities. It is not an asset freeze or a ban on ordinary commercial trade (e.g. Treasury NS-CMIC List).
On December 16, 2021, OFAC identified CloudWalk Technology Co., Ltd. as a Chinese Military-Industrial Complex Company and added it to the NS-CMIC List. The OFAC Sanctions List Search detail entry confirms the entity 'CLOUDWALK TECHNOLOGY CO., LTD.' (a.k.a. CLOUDWALK) on the Non-SDN list under program code CMIC-EO13959 (Executive Order 13959, as amended by Executive Order 14032). Identified for operating in the surveillance technology sector of the PRC economy; Treasury's stated rationale was active support for the biometric surveillance and tracking of ethnic and religious minorities in China, particularly Uyghurs in Xinjiang. Listed on the same date alongside seven other firms (Dawning Information Industry; Leon Technology; Megvii Technology; NetPosa Technologies; SZ DJI Technology; Xiamen Meiya Pico Information; Yitu Limited). SCOPE: this is an INVESTMENT/SECURITIES restriction only — it prohibits US persons from purchasing or selling publicly traded securities (and derivatives thereof) of the listed company. It is NOT an SDN designation, does NOT freeze assets, and does NOT broadly bar all dealings. A divestment wind-down deadline applied (no later than Dec 15, 2022). CloudWalk is on the Non-SDN/Consolidated list, NOT the SDN list. Verified against the OFAC Sanctions List Search detail record; no evidence of removal as of the research date.
OFAC Recent Actions, December 16, 2021 — Non-SDN Chinese Military-Industrial Complex Companies (NS-CMIC) List Updates