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 · 2020-12-18
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.
Added to the BIS Entity List (15 CFR Part 744, Supplement No. 4) under the China heading, subjecting exports, reexports, and transfers of items subject to the EAR to a license requirement; license review policy is case-by-case for items necessary to detect, identify, and treat infectious disease and presumption of denial for all other items. Listed as 'DJI' with aliases including 'SZ DJI Technology Co., Ltd.' Rule effective Dec 18, 2020; published in the Federal Register Dec 22, 2020.
Federal Register Vol. 85, No. 246 (Dec. 22, 2020), Doc. 2020-28031 — Addition of Entities to the Entity List
US Treasury (NS-CMIC)Investment restrictionNon-SDN Chinese Military-Industrial Complex Companies (NS-CMIC) List · 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).
Identified by OFAC as a Chinese Military-Industrial Complex Company under Executive Order 13959 (as amended by E.O. 14032), restricting U.S. persons from transacting in covered publicly traded securities of the entity. Listed as 'SZ DJI TECHNOLOGY CO., LTD.' with program tag [CMIC-EO13959] and Listing Date (CMIC) 16 Dec 2021. Determination dated Dec 16, 2021; published in the Federal Register Dec 22, 2021.
Federal Register Vol. 86, No. 243 (Dec. 22, 2021), Doc. 2021-27642 — OFAC NS-CMIC List Determinations