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 (15 CFR Part 744, Supplement No. 4) · 2019-10-09
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.
BIS added SenseTime (listed in the rule as 'Sense Time') to the Entity List effective October 9, 2019, as part of a final rule adding 28 China-based entities determined to be acting contrary to U.S. foreign-policy interests for their role in human-rights abuses against Uyghurs, Kazakhs, and other Muslim minority groups in the Xinjiang Uyghur Autonomous Region (XUAR). The listing imposes a license requirement for all items subject to the Export Administration Regulations (EAR), with a license-review policy of presumption of denial. This is an export-control restriction on supplying U.S.-origin (EAR-subject) items to the entity; it is NOT an asset-blocking sanction and does not by itself prohibit U.S. persons from transacting with or investing in the company. Corroborated by independent legal and press reporting (Winston & Strawn; TechCrunch). Listing remains in effect; not removed.
Federal Register: Addition of Certain Entities to the Entity List (84 FR 54002; Oct. 9, 2019; doc. 2019-22210)
US Treasury (OFAC)Investment restrictionNon-SDN Chinese Military-Industrial Complex Companies (NS-CMIC) List, program code CMIC-EO13959 · 2021-12-10
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 10, 2021 (listing date) OFAC added 'SENSETIME GROUP LIMITED' to the Non-SDN Chinese Military-Industrial Complex Companies (NS-CMIC) List under Executive Order 13959, as amended by E.O. 14032 (OFAC program field 'CMIC-EO13959'). Verified directly against OFAC's Sanctions List Search record (id=33114): Non-SDN list; program CMIC-EO13959; listing date 10 Dec 2021; effective date (CMIC securities-trading prohibition) 08 Feb 2022; divestment/wind-down date 10 Dec 2022; address Block 1, 1F & 2F Harbour View, 12 Science Park West Avenue, Hong Kong Science Park, Hong Kong SAR; C.R. No. 2162198; alias 'SENSETIME GROUP LTD.' The NS-CMIC designation prohibits U.S. persons from purchasing or selling publicly traded securities (and derivatives of, or securities designed to provide investment exposure to, such securities) of the listed entity. This is an investment/securities restriction on U.S. persons — it is NOT an asset-blocking SDN sanction (the entity is on the Non-SDN list, not the SDN list) and does not block the company's assets or impose a general transaction ban. The action coincided with SenseTime's Hong Kong IPO pricing; the U.S. government basis for the designation references an affiliate's facial-recognition capabilities. Listing remains in effect; not removed.
OFAC Sanctions List Search — SENSETIME GROUP LIMITED (Non-SDN / CMIC-EO13959), id=33114
SenseTime is NOT on the OFAC Specially Designated Nationals (SDN) blocking list — its OFAC listing is on the separate Non-SDN NS-CMIC list, which is an investment/securities restriction, not an asset freeze (verified via OFAC Sanctions List Search id=33114, which shows "Non-SDN"). SenseTime is NOT on the FCC Covered List. (Note: the FCC Covered List is an equipment-authorization restriction, not a flat sanction. As of the latest update verified, the list names Huawei, ZTE, Hytera, Hikvision, and Dahua and their subsidiaries/affiliates for telecommunications and video-surveillance equipment, plus Kaspersky Lab and the Chinese carriers China Mobile, China Telecom, Pacifica Networks/ComNet, and China Unicom; SenseTime is not among any of these.) No EU consolidated-sanctions, EU Sanctions Map, or EU member-state listing of SenseTime was located in this research (OpenSanctions shows only US listings; no EU designation). Only the two designations above — BIS Entity List (export control) and OFAC NS-CMIC (investment/securities restriction) — were verified against authoritative sources and are retained.