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… Read More

Retired General James “Spider” Marks Analyzes China’s Structure, Culture, and Intentions – and the United States’ Response

Last month, Retired General James “Spider” Marks joined China Tech Threat (CTT) as Principal. Over the course of his distinguished Army career, General Marks served America in a variety of roles in uniform, including as senior intelligence officer during Operation Iraqi Freedom in 2003 and as Commanding General of the U.S. Army Intelligence School in Fort Huachuca, Arizona.General Marks has spent decades observing China’s behavior. His statement he provided upon joining CTT in November shed light on his views of the United States’ evolving competition with China.Since posting that initial statement, we sat down to hear more about General Marks’ thoughts about the Chinese government’s structure, culture, and intentions – and the United States’ response. We encourage you to watch the series of five… Read More

YMTC and Other Companies Added to the Entity List

China Tech Threat Co-Founder Dr. Roslyn Layton issued the below statement following the U.S. Commerce Department’s announcement today 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 several other Chinese companies. “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. Blacklisting YMTC should be just a first step, as the effectiveness of this… Read More

Japan and the Netherlands Sign on to Export Controls; Will Multilateral Momentum for Them Continue at the WTO? 

For months the U.S. Commerce Department has exerted pressure on Japan and the Netherlands to restrict the sale of advanced chipmaking equipment to China. Now that the U.S. has issued its own tough export controls targeting the likes of “bellwether” chip companies YMTC, CXMT, and SMIC, Bloomberg reports that Japan and the Netherlands will join the U.S. in issuing restrictions of their own. The importance of this move should not be underestimated. Bloomberg’s analysis describes the addition of Japan and the Netherlands as a “significant milestone,” adding that, “the three-country alliance would represent a near-total blockade of China’s ability to buy the equipment necessary to make leading-edge chips.”China knows these crushing blows spell doom for its domestic production of advanced chips, so… Read More

New Report Links YMTC with Known Chinese Human Rights Violator

One year ago, a Hikvision-focused website noted that YMTC chips were being used in Hikvision products. This may not seem like a big deal on the surface – one Chinese company working with another company. It is a big deal. Why? Hikvision, an Entity Listed Chinese surveillance technology giant that’s complicit in some of the worst crimes against humanity of the 21st century, contains chips from YMTC, a “bellwether semiconductor firm” that’s on the path to the Entity List itself.Adding fuel to bipartisan calls to finally put YMTC on the Entity List is a new report from teardown specialist Tech Insights. EE News Europe reports, “‘Tear-down’ specialist Tech Insights has found an example of an YMTC (Xtacking 3.0) 232-layer… Read More


Is Commerce Getting Played By The Chinese Government On Export Controls?

China Tech Threat Co-Founder Dr. Roslyn Layton issued the below statement following the U.S. Commerce Department’s announcement today 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 several other Chinese companies. “The Commerce Department passed the 60-day window it set for itself to determine if PRC national champion chipmaker YMTC should be moved from the Unverified List to the Entity List. Its October 7 Export Control announcement seemed to signal a new era of enforcement at Commerce’s Bureau of Industry and Security (BIS), but praising ‘better behavior’ and ‘changes in attitude’ from China is not a strategy that will protect America’s national and economic security, especially given the Chinese… Read More

BIS is on the Clock: Experts Assess Export Controls, Effectiveness with Regard to China

We have 7 DAYS left in the BIS Countdown that started on October 7 when the Bureau issued long-awaited export controls targeting Chinese chipmakers. Will YMTC, a national champion chipmaker, and others on the Unverified List (UVL) allow for and pass end-use checks, or will they get put on the Entity List? That’s one of our big questions.Earlier this month, Roslyn Layton hosted a virtual event to dive into the new export controls and related issues with Nazak Nikakhtar (Partner and National Security Co-Chair, Wiley; former Department of Commerce Lead on CFIUS) and Dustin Carmack (Research Fellow, Heritage Foundation). They discussed the impact of the controls on China’s semiconductor capabilities, the Apple-YMTC relationship, and how the new Congress should… Read More

CXMT’s Inclusion in Section 889 Amendment Shows It’s a Growing Threat

As Roslyn Layton writes in her latest column for Forbes, a battle is raging in Washington, with concerned national security experts and bipartisan legislators on one side and K Street on the other.The U.S. Congress is currently crafting this year’s National Defense Authorization Act (NDAA) – the mammoth yearly bill that provides for America’s national defense. Senators Chuck Schumer and John Cornyn are leading the charge to expand a provision of the NDAA, Section 889, to ban the federal government from using chips from leading Chinese chipmakers SMIC, YMTC, and CXMT.It’s worth noting that in addition to calling for a ban on products made with chips made by SMIC and YMTC – both companies with known ties to… Read More

More U.S. Pressure Coming on YMTC – Will American Allies Join In?

YMTC is firmly in the crosshairs of both the executive and legislative branches of the U.S. government. Will the desire to stop one of the world’s most dangerous companies go international?Ever since the Biden Administration unleashed a new round of export controls targeting the Chinese semiconductor chip industry on October 7, Chinese firms have been buckling under the weight of the new restrictions. For example, the South China Morning Post reports that “China’s chip output in October reached 22.5 billion units, down 26.7 per cent from a year ago and the largest single-month decrease on record.”More actions from the executive branch seem likely. This week, Bureau of Industry and Security Assistant Secretary Matthew Axelrod is quoted by Reuters… Read More

CTT Quick Cut Wrap Up: Experts Assess Implications of Export Controls for YMTC, Apple

The U.S. is at a key moment with its China-focused export control policy. On October 7, the Commerce Department issued a slew of new regulations targeting China’s semiconductor industry, triggering a crucial 60-day period when Commerce Department will decide whether to add firms like YMTC and CXMT to the Entity List.Meanwhile, a new Congress looks poised to exert pressure on Commerce to maintain a tough stance, with the potential new chairman of the House Foreign Affairs Committee, Michael McCaul, saying he will be “focused like a laser on export control issues.” And the New York Times wants to know if Apple will permanently step back from a dangerous Apple-YMTC deal, but Apple hasn’t yet commented.On November 15, CTT’s… Read More