U.S. government agencies, defense contractors, federal contractors, financial institutions, and any organization that interacts with, invests in, or procures from entities identified under NDAA Section 1260H (Chinese military companies) or Section 889 (prohibited telecommunications and video surveillance equipment).
The NDAA includes multiple provisions restricting engagement with entities tied to foreign adversaries. Section 1260H requires the Secretary of Defense to identify Chinese military companies operating in the United States — entities owned, controlled, or affiliated with the People's Liberation Army (PLA) or China's defense industrial base. The list triggers investment restrictions (Executive Order 14032), procurement prohibitions, and enhanced due diligence requirements. Section 889 of the FY2019 NDAA prohibits federal agencies and contractors from procuring or using telecommunications and video surveillance equipment from Huawei, ZTE, Hytera, Hikvision, Dahua, and their subsidiaries and affiliates.
Screen entities against the DoD's Section 1260H list and Section 889 covered entities with matching that handles Chinese corporate naming conventions, aliases, and subsidiary structures.
Identify subsidiaries and affiliates of listed companies that may not be named on the lists themselves but are subject to the same restrictions.
Track PLA-affiliated and covered entities across corporate structures that span multiple jurisdictions, including those with opaque ownership through Hong Kong, Macau, and offshore intermediaries.
Generate reports documenting the screening process and findings for compliance records and procurement due diligence.
Requires defense contractors and cleared companies to disclose and mitigate foreign ownership, control, or influence — including indirect relationships through board seats, financial ties, and technology agreements.
Prohibits transactions with designated individuals, entities, and jurisdictions across OFAC, EU, UK, and UN sanctions lists — requiring continuous screening of counterparties, suppliers, and beneficial owners.
Controls the export and re-export of dual-use and defense-related items under EAR and ITAR, requiring end-user screening, item classification, and documentation to prevent controlled goods from reaching prohibited destinations.