On 26th August, Squire Patton Boggs published a briefing about 2 new Rules that add and revise a total of 46 of Huawei Technologies Co Ltd non-US affiliates and extend the deadline and clarifies the scope of the previously issued Temporary General License (TGL) for Huawei and the Huawei Listed Companies. It goes on to explain that designation of an organisation on the Entity List does not block all dealings with the organisation, as would be the case for an organisation designated as a Specially Designated National (SDN) by OFAC. The Entity List is more targeted in its application. It prohibits all exports from the US to the Huawei Listed Companies, and includes items of foreign origin in the US temporarily. While the designation applies to all items in the US, it does not apply to all foreign-made items.
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