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 · 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.
Zhejiang Dahua Technology Co., Ltd. was added to the BIS Entity List effective October 9, 2019 (84 FR 54002, rule 2019-22210). The listing imposes a license requirement for all exports, reexports, and in-country transfers of items subject to the Export Administration Regulations (EAR), with a license review policy of presumption of denial, and no license exceptions available. This is an export-control restriction, not a sanction or asset freeze. Verified against the official Federal Register rule text (govinfo.gov mirror confirms the presumption-of-denial policy and all-items-subject-to-the-EAR scope).
Addition of Certain Entities to the Entity List, 84 FR 54002 (Oct. 9, 2019) (BIS rule 2019-22210; primary text mirrored at govinfo.gov/content/pkg/FR-2019-10-09/pdf/2019-22210.pdf)
US FCCEquipment-authorization restrictionCovered List (Secure and Trusted Communications Networks Act, Section 2) · 2021-03-12
Covered equipment cannot receive new FCC authorization for certain purposes. It is not a sanction or asset freeze and does not ban all of the company’s products (e.g. FCC Covered List).
Video surveillance and telecommunications equipment produced or provided by Dahua Technology Company (including its subsidiaries and affiliates) was placed on the FCC Covered List on March 12, 2021, but ONLY to the extent it is used for the purpose of public safety, security of government facilities, physical security surveillance of critical infrastructure, and other national security purposes (tracking the statutory scope of 2019 NDAA Section 889(f)(3)(B)). This is an equipment-authorization restriction under the FCC equipment authorization program (covered equipment cannot be authorized for sale/import for those purposes); it is NOT a flat sanction and does not prohibit all Dahua products in the U.S. Scope and date corroborated by the FCC Covered List page and the FCC PSHSB public notice DA-21-309, and by OpenSanctions structured data (listed 2021-03-12).
List of Equipment and Services Covered By Section 2 of The Secure Networks Act (FCC Covered List)
No US OFAC SDN designation and no EU consolidated-sanctions designation on public record as of the research date. Crucially, Dahua is NOT on the US Treasury OFAC Non-SDN Chinese Military-Industrial Complex Companies (NS-CMIC) list: I downloaded and searched the authoritative OFAC consolidated sanctions list data file (cons_prim.csv, 68 CMIC-EO13959 entries) and the OFAC SDN list (sdn.csv) directly, and found zero matches for "Dahua" or "Zhejiang Dahua" in either; only Hangzhou Hikvision Digital Technology Co., Ltd. appears on the NS-CMIC list (CMIC listing date 03 Jun 2021). Several secondary commentaries incorrectly claim Dahua is in the Executive Order 14032 annex, but this conflates Dahua with Hikvision and is refuted by the primary OFAC data, so no investment-restriction designation is included here. (Separately, the US DOD has listed Dahua on its Section 1260H Chinese Military Companies list since 2022-10-05; the 1260H list is a statutory identification rather than an export-control / sanction / equipment-authorization / investment restriction among the named authorities for this record, so it is not reported in the designations array. No customer/deployment claims and no individual PII below corporate-officer level are included.)