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.
Megvii Technology added to the Bureau of Industry and Security (BIS) Entity List effective Oct 9, 2019 (84 FR 54002; rule 2019-22210; Docket No. 190925-0044; RIN 0694-AH68), as one of 28 PRC entities determined to be acting contrary to U.S. foreign-policy interests in connection with high-technology surveillance and human-rights abuses against Uyghur and other Muslim minority groups in Xinjiang. A license is required for all items subject to the EAR for exports, reexports, and transfers (in-country), with a presumption of denial (case-by-case review for a limited set of ECCNs and certain EAR99 items). This is an export-control licensing restriction, NOT an asset freeze, an OFAC sanction, or a flat trade ban.
Federal Register, 84 FR 54002 (Oct. 9, 2019): Addition of Certain Entities to the Entity List (rule 2019-22210)
US Treasury (OFAC)Investment restrictionNon-SDN Chinese Military-Industrial Complex Companies List (NS-CMIC) · 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 Dec 16, 2021, the U.S. Treasury (OFAC) identified Megvii Technology Limited as one of eight Chinese technology firms and added it to the NS-CMIC List pursuant to Executive Order 13959 (as amended by E.O. 14032), for operating or having operated in the surveillance technology sector of the PRC economy. The designation prohibits U.S. persons from purchasing or selling publicly traded securities (and certain derivatives) of the company; the divestment/wind-down period ran for 365 days. This is a securities-investment restriction, NOT an OFAC SDN asset-blocking sanction (Megvii is on the Non-SDN list, so assets are not frozen).
U.S. Department of the Treasury Press Release JY0538: Treasury Identifies Eight Chinese Tech Firms as Part of the Chinese Military-Industrial Complex (Dec. 16, 2021)