Effective November 18, 2019, the US Commerce Department’s Bureau of Industry and Security (“BIS”) issued a final rule extending by 90 days through February 16, 2020 the validity of the Temporary General License (“TGL”) authorizing certain transactions involving the export, reexport, and transfer of items subject to the Export Administration Regulations to Chinese-headquartered Huawei Technologies Co. Ltd. (“Huawei”) and one hundred and fourteen of its non-US affiliates designated on the BIS Entity List. The TGL had been set to expire on November 18, 2019.

Please see our prior blog posts on the initial designation of Huawei and sixty-eight of its non-US affiliates to the Entity List on May 16, 2019 here; on the issuance of the original TGL on May 20, 2019 here; on the designation of forty-six additional non-US affiliates of Huawei to the Entity List and on the TGL updates issued on August 19, 2019 here; and on BIS’s publication of Huawei-related FAQs on September 9, 2019 here.

Since this extension of the TGL, BIS has reportedly begun issuing some individual licenses to authorize limited and specific activities which do not impose a significant risk to US national security or foreign policy interests, but has also stated that it intends to deny other license applications.