“If you’re using a tool, and you’re still seeing the problematic behavior, you do have to consider using a harsher tool,” says Emily Kilcrease, a senior fellow at CNAS and former U.S. Trade Representative official. She points out that Iran provides an interesting precedent: “It got to a certain point with Iran that we broke the seal a little bit in terms of doing SDN listings,” she says. “Are we now at that point with China?”That job of enforcement and coordination is only getting harder.
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Over the last year, the U.S. government has expanded its use of export controls against both China and Russia — around 150 Chinese companies have been added to the Entity list since the beginning of the Biden administration, according to data compiled by the Center for a New American Security (CNAS), and about 450 Russian and Belarusian entities have been placed on the Entity List since the Ukraine invasion.
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