Commerce Department Suspends Exports to Belgian Company Attempting to Send U.S. Technology to China – Kharon Brief

By Robert Kim
September 14, 2022
On September 1, the U.S. Commerce Department’s Bureau of Industry and Security (BIS) published an order temporarily denying the export privileges of a Belgian businessman and his company after discovering attempts to obtain controlled U.S.-origin devices for Chinese end users on the BIS Entity List. 
The BIS Office of Export Enforcement (OEE) found that Hans De Geetere of Belgium and his company Knokke-Heist Support Corporation Management made numerous attempts in 2020-2022 to obtain accelerometers from a U.S. company.  Accelerometers – sensors that measure acceleration – are widely used in navigation and avionics systems by the aerospace industry, including in navigation for aircraft and missiles and stabilization of unmanned aerial vehicles (UAVs). BIS identifies accelerometers as an item subject to export controls.
China Aerospace Research Institute (CARI) was one of the intended end users of U.S.-origin accelerometers that De Geetere and Knokke-Heist attempted to acquire in 2020, according to BIS. CARI attempted to order accelerometers from a U.S. company, which rejected the order. Shortly afterward, in November 2020, De Geetere and Knokke-Heist attempted to obtain the same quantity and model of accelerometers from the U.S. company’s German distributor. 
BIS “has reason to believe” that CARI is connected to or is an alias for the China Aerospace Science and Technology Corporation (CASC) 1st Academy 12 Research Institute, which has been on the Entity List since 1999. 
CASC is a state-owned entity that is reportedly the primary contractor for the Chinese space program. CASC, which has numerous research institutes, departments, and other units, was designated a Non-SDN Chinese Military-Industrial Complex Company (NS-CMIC) by U.S. executive order and OFAC action in June 2021. Inclusion on the NS-CMIC List subjects CASC to sanctions under the executive order. Additional CASC research institutes were added to the Entity List in August of this year, as Kharon previously reported.
Shanghai Nova Instruments Company, Ltd. was another intended end user of U.S.-origin accelerometers that De Geetere and Knokke-Heist attempted to acquire, according to BIS. Shanghai Nova was formerly a Chinese distributor for the U.S. company that rejected CARI’s order for accelerometers. In June 2020, Shanghai Nova was placed on the Entity List for being involved in the procurement without required licenses of items for possible use in missile and UAV applications in China. Subsequently, in July 2020, De Geetere and Knokke-Heist ordered approximately $360,000 worth of accelerometers from the same U.S. company’s German distributor. 
Further attempts by De Geetere and Knokke-Heist to purchase accelerometers, with false documentation or purchases through entities in third countries, took place in 2021-2022
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