2022 End of Year Newsletter

Chinese Military-Aligned Chipmaker YMTC Added To Entity List – At Last. On December 15 – after blowing by a self-imposed December 6 deadline – the U.S. Commerce Department announced that YMTC, a state-backed chip maker with close ties to the People’s Liberation Army (PLA), has been added to the Entity List, along with other Chinese companies. The announcement comes not a day too soon as CTT co-founder Dr. Roslyn Layton said in a statement: “The addition of YMTC, a Chinese military-aligned chip maker, to the Entity List is long-awaited and critical from both national and economic security standpoints. With today’s announcement, the Bureau of Industry and Security (BIS) is putting a long-overdue focus on our national security under the leadership of Under Secretary Alan Estevez. Today’s news is a declaration that American security matters more than corporate profits.”

After YMTC, Export Control Action Must Continue With Focus On CXMT, The Most Dangerous Chinese Company You Haven’t Heard Of. Following the YMTC Entity List news, CTT urged BIS to continue to pursue Entity List designations for other dangerous Chinese military chipmakers, such as Changxin Memory Technologies (CXMT). In a blog, CTT highlighted the work by Senators Chuck Schumer and John Cornyn to expand a provision of the NDAA, Section 889, to ban the federal government from using chips from leading Chinese chipmakers such as CXMT as evidence it is a growing threat. In a Forbes column, Dr. Layton cites a conversation with Rear Admiral (Ret.) Mark Montgomery, who remarked, “We have to make sure that our federal government networks and national critical infrastructure assets are free of Chinese-made chips. A voluntary appeal is not going to work.”

2023: State Momentum Builds To Ban Chinese Technology. With Georgia Bill SB 346 signed into law by Governor Brian Kemp in May, the adoption of model policy by the American Legislative Exchange Council (ALEC) in July, and Florida Governor Ron DeSantis issuing an executive order in September, steady momentum is building at the state level to restrict state contracts with Chinese government-owned tech companies. Other states have also taken action, as analyzed by the Heritage Foundation’s Michael Cunningham, and CTT expects 2023 will see several other states taking decisive action to bolster defenses against instruction. Stay tuned for developments from CTT and more updates to our research on state contracts with banned Chinese tech manufacturers in 2023.  

New Entity List Highlights Lenovo Connections To Chinese Military, Nuclear, Cyberespionage. In a new Forbes column on the Chinese Academy of Sciences (CAS) being among the new Entity List designations announced by the U.S. Department of Commerce, Dr. Roslyn Layton draws attention to the threat posed by Lenovo, “a textbook example of China’s techno-nationalist strategy to leverage its global companies for military gain.” Lenovo, she writes, is the brainchild of CAS – the Chinese-government’s crown jewel institution of scientific research which has connections to Chinese military, nuclear, and cyberespionage programs. “It owns whole companies building technology for the Chinese military, as if the Pentagon and MIT teamed up” and should be next on the Entity List writes Layton. 


CTT Welcomes Retired General James “Spider” Marks As Principal.  In November, CTT welcomed Gen. Marks – who served as senior intelligence officer during Operation Iraqi Freedom in 2003 and as Commanding General of the U.S. Army Intelligence School – as its principal. In a statement on his new role, Gen. Marks stated: “Over the course of my career in the U.S. military, I watched U.S. military planners go from regarding China a second-tier challenge to treating it as our pacing threat. Though I am no longer in uniform, I remain committed to defending the American way of life and ensuring that my own children and grandchildren can live in security and freedom. Protecting America from technology-related threats emanating from China is imperative.” To learn more about his perspective in his own words, watch a series of videos here