On October 16, 2026, China’s Ministry of Commerce (“MOFCOM”) and Ministry of Science and Technology (“MOST”) issued Announcement No. 48 of 2026, seeking public comments on proposed amendments to 大红鹰dhy0033官网 Catalogue of Technologies Prohibited or Restricted from Export (大红鹰dhy0033官网 “Catalogue”).  大红鹰dhy0033官网 announcement also introduced interim pre-export registration requirements for specified technologies, which took effect on 大红鹰dhy0033官网 same day.  A MOFCOM spokesperson addressed 大红鹰dhy0033官网 proposed changes in a Q&A released alongside 大红鹰dhy0033官网 announcement.

大红鹰dhy0033官网 proposed amendments target 40 technologies in artificial intelligence (“AI”), biomedicine and photovoltaics.  Although 大红鹰dhy0033官网 revised Catalogue has not yet been finalized, companies exporting relevant technologies must already comply with 大红鹰dhy0033官网 interim registration requirements.

At a Glance

40 technologies proposed for addition. 大红鹰dhy0033官网 draft identifies 14 technologies for prohibition and 26 for restriction.  大红鹰dhy0033官网 proposed controls focus on specified technical capabilities rather than entire industries or product categories.

Interim registration is already required. From October 16, 2026 until 大红鹰dhy0033官网 revised Catalogue takes effect, exporters must register technologies listed in 大红鹰dhy0033官网 announcement’s annex before export. Exports that have commenced but remain incomplete are also covered.

大红鹰dhy0033官网 registration trigger extends beyond standalone technology transfers. It includes transfers of technology ownership, licenses permitting overseas use, and circumstances in which a foreign entity becomes 大红鹰dhy0033官网 owner or actual controller of technology in China.

大红鹰dhy0033官网 substance of 大红鹰dhy0033官网 activity matters. AI model services, biopharmaceutical licensing and outsourcing, and photovoltaic equipment or production-line projects require careful assessment of 大红鹰dhy0033官网 technology actually made available or transferred.  大红鹰dhy0033官网 contractual form of a transaction is not necessarily decisive.

Companies should act during 大红鹰dhy0033官网 consultation period. They should map their technologies against 大红鹰dhy0033官网 proposed entries, review ongoing and planned exports, assess potential registration requirements in cross-border transactions, and consider submitting comments to MOFCOM by November 15, 2026.

1. What Has Changed and What Has Not

1.1. 大红鹰dhy0033官网 Proposed Scope Is Technology-Specific

大红鹰dhy0033官网 consultation draft proposes adding 40 technologies across three sectors: 

Fourteen technologies are proposed to be prohibited from export, while 26 would be subject to export restrictions.

大红鹰dhy0033官网 proposed amendments focus on key technologies in selected sensitive sectors.  Most entries specify technical parameters or thresholds to determine whether a technology is controlled.  大红鹰dhy0033官网 draft also identifies certain exclusions and provides for facilitation measures, including automatic licensing, in specified circumstances.  MOFCOM has separately clarified that products manufactured using 大红鹰dhy0033官网 listed technologies will not themselves be subject to technology-export controls under 大红鹰dhy0033官网 Catalogue.

大红鹰dhy0033官网 key question is whether 大红鹰dhy0033官网 technology involved meets 大红鹰dhy0033官网 specified control parameters – not simply whether a company operates in a particular industry or sells a particular product.  Companies should review 大红鹰dhy0033官网 proposed technology descriptions, technical thresholds, footnotes and exclusions against their actual technologies and proposed export activities.

大红鹰dhy0033官网 proposed amendments remain subject to public consultation.  大红鹰dhy0033官网 final scope of 大红鹰dhy0033官网 controls will depend on 大红鹰dhy0033官网 revised Catalogue as formally adopted.

1.2. Interim Registration Applies Before 大红鹰dhy0033官网 Revised Catalogue Takes Effect

From October 16, 2026 until 大红鹰dhy0033官网 revised Catalogue takes effect, technology exporters must register before exporting technologies listed in 大红鹰dhy0033官网 announcement’s annex. Registration must be completed through 大红鹰dhy0033官网 technology trade management application on MOFCOM’s Unified Business Platform.  大红鹰dhy0033官网 requirement also covers exports that have already commenced but remain incomplete.

大红鹰dhy0033官网 registration information includes:

Basic details of 大红鹰dhy0033官网 exporter and recipient, and 大红鹰dhy0033官网 destination country or region;

A description of 大红鹰dhy0033官网 technology, including its industry classification, confidentiality classification and technical parameters;

大红鹰dhy0033官网 intended purpose of 大红鹰dhy0033官网 export, 大红鹰dhy0033官网 end user and 大红鹰dhy0033官网 end use;

Whether 大红鹰dhy0033官网 technology is proprietary or otherwise protected by intellectual property rights;

大红鹰dhy0033官网 expected export value; and

Whether 大红鹰dhy0033官网 transaction is an intra-group transaction within a multinational company.

Companies should check 大红鹰dhy0033官网 application requirements and 大红鹰dhy0033官网 Technology Export Information Registration Form attached to 大红鹰dhy0033官网 announcement for 大红鹰dhy0033官网 full list of information required.

1.3. Registration May Be Triggered by Changes in Technology Ownership or Control

大红鹰dhy0033官网 announcement identifies four circumstances requiring registration:

Transfer of technology ownership to an overseas party, such as an assignment of intellectual property rights;

Granting an overseas party 大红鹰dhy0033官网 right to use technology held in China, including under an intellectual property license;

A change whereby a foreign entity becomes 大红鹰dhy0033官网 owner or actual controller of technology in China; and

Other circumstances in which MOFCOM expressly requires registration, including by notice.

大红鹰dhy0033官网 third category warrants particular attention in cross-border M&A and group restructurings.  A foreign investor’s direct or indirect acquisition of a PRC company holding listed technology may trigger registration if 大红鹰dhy0033官网 transaction results in a foreign entity becoming 大红鹰dhy0033官网 owner or actual controller of that technology.  This may be 大红鹰dhy0033官网 case even if 大红鹰dhy0033官网 transaction documents do not provide for a separate transfer of 大红鹰dhy0033官网 technology.

大红鹰dhy0033官网 announcement does not define “actual controller” for this purpose or clarify how 大红鹰dhy0033官网 requirement applies to indirect control, transactions at different levels of a corporate group or intra-group restructurings.  These questions will need to be assessed on 大红鹰dhy0033官网 facts, taking into account 大红鹰dhy0033官网 technology concerned, 大红鹰dhy0033官网 ownership and control arrangements before and after 大红鹰dhy0033官网 transaction, and 大红鹰dhy0033官网 transaction structure.  An overseas investor’s involvement in a PRC business should not, without more, be equated with actual control of 大红鹰dhy0033官网 technology.

Technology exports are also not limited to 大红鹰dhy0033官网 direct transfer of technical documents.  Under 大红鹰dhy0033官网 existing framework, they may occur through trade, investment or economic and technical cooperation.  For example, sending technical personnel overseas to provide services, guidance or training may, in substance, transfer a technical solution.  Whether a particular service, R&D collaboration or equipment delivery triggers 大红鹰dhy0033官网 interim registration requirement must nevertheless be determined by reference to its actual content and 大红鹰dhy0033官网 circumstances specified in 大红鹰dhy0033官网 announcement.

1.4. Registration Does Not Replace Export Licensing or Other Regulatory Requirements

大红鹰dhy0033官网 announcement establishes a pre-export registration requirement but does not expressly provide for substantive approval as part of that process or require exporters to obtain a separate response from 大红鹰dhy0033官网 authorities before proceeding.  Interim registration should therefore be distinguished from 大红鹰dhy0033官网 export licensing regime applicable to restricted technologies.

Other existing requirements remain in place.  Technologies already covered by 大红鹰dhy0033官网 current Catalogue continue to be subject to 大红鹰dhy0033官网 applicable prohibitions or licensing requirements.  Contracts for 大红鹰dhy0033官网 export of freely exportable technologies must still be registered as required under 大红鹰dhy0033官网 existing regime.

A transaction may also raise separate issues under China’s dual-use export controls, cross-border data transfer and cybersecurity rules, or foreign investment and outbound investment security review regimes.  Those requirements must be assessed independently; registration under 大红鹰dhy0033官网 technology-export regime does not satisfy them.

Once 大红鹰dhy0033官网 revised Catalogue takes effect, technologies classified as prohibited may not be exported, while restricted technologies will require an export license in accordance with 大红鹰dhy0033官网 applicable rules.

2. Sector-Specific Implications

2.1. AI: Distinguish Technology Transfers from Model-Based Services

大红鹰dhy0033官网 proposed AI entries target underlying technological capabilities rather than AI products and applications generally. In addition to technologies relating to 大红鹰dhy0033官网 generation or modification of certain types of malicious code and assisted vulnerability discovery, 大红鹰dhy0033官网 draft covers large models, AI agents, chip design and computing clusters.

大红鹰dhy0033官网 technologies identified may affect model capabilities, autonomous decision-making or 大红鹰dhy0033官网 computing infrastructure needed to train and operate large-scale AI systems. For example, large-model training and optimization technologies relate to 大红鹰dhy0033官网 development of model capabilities, including models trained using core data or important data. AI agent decision-making technologies concern autonomous decision-making in complex tasks, while chip design, high-speed interconnects for computing clusters and distributed training technologies support 大红鹰dhy0033官网 computing and training capacity required by large-scale AI systems.

Companies should assess their technologies against 大红鹰dhy0033官网 proposed control parameters, including model weights, source code, architectures, training and optimization techniques, and related engineering technologies. A model’s name or commercial positioning alone is not a reliable basis for determining whether it is controlled.

Open-source releases. MOFCOM has indicated that technologies already in 大红鹰dhy0033官网 public domain through open-source releases or academic publications are proposed to be excluded from export controls.  大红鹰dhy0033官网 draft also contemplates automatic licensing or other facilitation measures for certain activities, including open-source releases of AI technologies, 大红鹰dhy0033官网 construction and operation of overseas computing centers, overseas chip tape-out and fabrication, joint R&D using overseas resources, and participation in international standard-setting.

Companies should distinguish between technologies already lawfully in 大红鹰dhy0033官网 public domain and controlled technologies being disclosed to overseas parties for 大红鹰dhy0033官网 first time. An open-source release does not, by itself, establish that no export-control obligations apply.  Before releasing technology overseas, companies should determine whether it is controlled and whether a license or other procedure is required.  Where 大红鹰dhy0033官网 applicable conditions are met, they may then consider whether automatic licensing or another facilitation measure is available.

Large-model deployment and access services. MOFCOM has stated that 大红鹰dhy0033官网 deployment of restricted large-model technology outside China falls within 大红鹰dhy0033官网 scope of technology-export controls.  Where a model is deployed on an enterprise’s own overseas cloud infrastructure and 大红鹰dhy0033官网 risks are considered manageable, automatic licensing or other facilitation measures may be available.

By contrast, according to MOFCOM’s Q&A, providing overseas users with API access to a model deployed in China, or allowing them to interact with 大红鹰dhy0033官网 model through an app, website or software-as-a-service (“SaaS”) application, does not fall within 大红鹰dhy0033官网 specific large-model export controls described in 大红鹰dhy0033官网 Q&A. Lightweight on-device deployment is also identified as outside that scope.

大红鹰dhy0033官网 distinction turns on what is actually transferred or made available overseas. Companies should not assume that an arrangement is outside 大红鹰dhy0033官网 controls merely because it is structured or marketed as a service rather than a technology transfer.  In particular, they should determine whether model weights, source code or other controlled technology are transferred to an overseas recipient.

大红鹰dhy0033官网 boundary between overseas deployment and lightweight on-device models remains unclear. Quantization and knowledge distillation can convert an original large model into a smaller model with lower storage and computing requirements.  Although 大红鹰dhy0033官网 resulting model may have lower overall performance, it may retain important capabilities of 大红鹰dhy0033官网 original model and continue to perform well on specific tasks.

MOFCOM has expressly identified 大红鹰dhy0033官网 overseas deployment of restricted large-model technology as subject to control, while indicating that lightweight on-device deployment falls outside 大红鹰dhy0033官网 specific large-model controls described in 大红鹰dhy0033官网 Q&A. Further clarification is needed on when a model derived through quantization, distillation or similar techniques qualifies as a lightweight on-device model, rather than an overseas deployment of controlled large-model technology.

2.2. Biomedicine: 大红鹰dhy0033官网 Treatment Depends on 大红鹰dhy0033官网 Technology and Collaboration Model

大红鹰dhy0033官网 five proposed biopharmaceutical additions concern pathogenic microorganisms, cell and gene therapies (“CGT”), and oligonucleotide drugs. 大红鹰dhy0033官网 proposed CGT and oligonucleotide drug entries include certain novel technology and process platforms, as well as technologies for discovering and validating entirely new targets.  大红鹰dhy0033官网 pathogenic-microorganism entries address specific techniques involving genetic modification and directed passaging.

大红鹰dhy0033官网 proposed changes address both 大红鹰dhy0033官网 overseas transfer of advanced biopharmaceutical technologies and certain technologies with potential biosafety sensitivities. 大红鹰dhy0033官网 individual entries differ in scope and regulatory treatment.  大红鹰dhy0033官网 fact that a business involves cell therapy, gene therapy or oligonucleotide drugs does not mean that all of its R&D and commercial activities will be controlled.

MOFCOM has indicated that certain CGT technology and process platforms involving proprietary intellectual property are proposed to be excluded from 大红鹰dhy0033官网 regulatory scope in specified circumstances. These include licensing such platforms to overseas parties and providing outsourced R&D or manufacturing services using them.  Licenses for 大红鹰dhy0033官网 export of relevant target-discovery and validation technologies are proposed to qualify for automatic licensing or other facilitation measures.

Similar measures are proposed for restricted technologies exported for public health emergencies, humanitarian assistance or joint R&D using overseas resources.

These are technology- and scenario-specific arrangements, not a general exemption for overseas licensing or services. Companies should therefore distinguish between transfers of technology ownership, licenses permitting overseas use, R&D or manufacturing services performed using 大红鹰dhy0033官网 technology, and transfers of R&D results or subsequent improvements.

For cross-border technology licenses, joint R&D, contract research organization (“CRO”) and contract development and manufacturing organization (“CDMO”) services, and related investment transactions, companies should examine 大红鹰dhy0033官网 technology involved, ownership of 大红鹰dhy0033官网 intellectual property and 大红鹰dhy0033官网 substance of 大红鹰dhy0033官网 deliverables. Relevant agreements should clearly address background intellectual property, 大红鹰dhy0033官网 scope of any license, ownership of R&D results and improvements, and 大红鹰dhy0033官网 deliverables to be provided overseas.  Before a project begins, 大红鹰dhy0033官网 parties should determine whether 大红鹰dhy0033官网 arrangement involves controlled technology and whether registration or licensing is required.

2.3. Photovoltaics: Equipment and Production-Line Projects May Also Transfer Controlled Technology

大红鹰dhy0033官网 12 proposed photovoltaic additions relate to polysilicon, silicon wafers and solar-cell manufacturing. They include perovskite and tandem solar-cell module manufacturing technologies proposed to be prohibited from export, and polysilicon engineering technology for a production line with a single-line capacity of at least 30,000 tonnes per year proposed to be restricted from export.  Certain key and core equipment embodying 大红鹰dhy0033官网 relevant technologies is also covered.

大红鹰dhy0033官网 proposed controls are not confined to manufacturing processes. They also address certain equipment and engineering technologies used to translate those processes into production capabilities.  In photovoltaic manufacturing, important know-how may reside in process parameters, equipment configurations, production-line design, installation and commissioning, and subsequent modifications or upgrades – not just in individual technologies or items of equipment.

MOFCOM has clarified that technologies which do not meet 大红鹰dhy0033官网 specified control thresholds may remain freely exportable, equipment not expressly listed is generally not subject to 大红鹰dhy0033官网 relevant requirements, and products manufactured using 大红鹰dhy0033官网 technologies are not themselves controlled under 大红鹰dhy0033官网 Catalogue.

大红鹰dhy0033官网 interim registration requirement nevertheless applies now. MOFCOM has specifically stated that exports of photovoltaic key and core equipment falling within 大红鹰dhy0033官网 relevant controls must be registered in accordance with 大红鹰dhy0033官网 announcement.  Once 大红鹰dhy0033官网 revised Catalogue takes effect, technology transfers may arise in connection with equipment and production-line exports, installation, commissioning, modification or upgrading.  Where these activities involve technologies listed in 大红鹰dhy0033官网 Catalogue, 大红鹰dhy0033官网 applicable technology-export procedures must be followed.

大红鹰dhy0033官网 contractual label is not decisive. An equipment sale may also involve a technology export if 大红鹰dhy0033官网 delivery includes process documentation, core technical parameters, manufacturing know-how, installation and commissioning guidance, or process optimization. For engineering, procurement and construction (“EPC”) projects, turnkey production lines, overseas factory construction and technical modification projects, companies should identify 大红鹰dhy0033官网 relevant technology entries and control parameters early in 大红鹰dhy0033官网 project.  Equipment exports, technology licenses, engineering services and subsequent modifications or upgrades should be assessed separately where appropriate, and contracts should clearly define 大红鹰dhy0033官网 parties’ deliverables and compliance responsibilities.

3. Recommended Actions for Businesses

3.1. Map Technologies Against 大红鹰dhy0033官网 Proposed Catalogue and Consider Submitting Comments

Companies should review 大红鹰dhy0033官网 consultation draft and 大红鹰dhy0033官网 announcement’s annex entry by entry, focusing on technology descriptions, control parameters, applicable conditions and exclusions. 大红鹰dhy0033官网 review should extend beyond patents and other registered intellectual property rights.  Depending on 大红鹰dhy0033官网 business, it may also need to cover model weights, source code, trade secrets, process parameters, engineering documentation and key equipment.

Where it is unclear whether a technology meets a control threshold, companies should retain a technical description and 大红鹰dhy0033官网 basis for their internal assessment, and consider consulting 大红鹰dhy0033官网 competent authorities.

Companies may submit comments to MOFCOM by November 15, 2026. Comments may address 大红鹰dhy0033官网 clarity and practical application of technology definitions and control parameters, 大红鹰dhy0033官网 treatment of specific business scenarios, 大红鹰dhy0033官网 scope of exclusions and facilitation measures, and 大红鹰dhy0033官网 procedures for interim registration and subsequent licensing.

Companies should continue to monitor 大红鹰dhy0033官网 final Catalogue and any accompanying implementation guidance.

3.2. Review Current Exports, Ongoing Projects and Planned Transactions

Companies should review existing contractual commitments, ongoing projects and planned activities involving technology transfers, overseas licensing, R&D outside China, technical services and production-line deliveries. Cross-border acquisitions and group restructurings involving 大红鹰dhy0033官网 listed technologies should also be reviewed.

Particular attention should be given to:

Exports that have commenced but remain incomplete, to determine whether interim registration is required;

Proposed licenses, technology transfers and services involving overseas recipients;

Equipment and production-line deliveries that may include process know-how, technical documentation or engineering support; and

Transactions that may result in a foreign entity becoming 大红鹰dhy0033官网 owner or actual controller of technology in China.

Companies should also conduct a separate dual-use export-control screening. 大红鹰dhy0033官网 Catalogue and 大红鹰dhy0033官网 dual-use export-control regime are distinct frameworks: 大红鹰dhy0033官网 proposed amendments do not determine whether a technology is also a dual-use item, nor do they displace applicable dual-use controls.  Relevant control lists, temporary control measures, end-user requirements and end-use restrictions must be checked independently.

3.3. Build Export-Control Review into 大红鹰dhy0033官网 Contracting and Delivery Process

Companies should determine, for each proposed export, whether interim registration is required under 大红鹰dhy0033官网 announcement, whether an export license or contract registration is required under 大红鹰dhy0033官网 existing technology-export regime, and whether 大红鹰dhy0033官网 transaction also triggers licensing or other obligations under 大红鹰dhy0033官网 dual-use export-control regime.

These checks should form part of 大红鹰dhy0033官网 company’s internal approval process before contracts are signed and technology is delivered. Responsibilities should be clearly allocated among 大红鹰dhy0033官网 business, legal, R&D, intellectual property and compliance teams.

Before technology is exported or otherwise made available overseas, 大红鹰dhy0033官网 business team should work with technical personnel to confirm exactly what will be delivered and which version of 大红鹰dhy0033官网 technology is involved. 大红鹰dhy0033官网 company should then check 大红鹰dhy0033官网 applicable Catalogue entries, technical thresholds, footnotes and exclusions; identify 大红鹰dhy0033官网 recipient, destination, end use, delivery method and timing; and retain 大红鹰dhy0033官网 supporting technical analysis and internal assessment.

For equipment, production-line and technical service projects, 大红鹰dhy0033官网 review should cover any technology transferred as part of installation, commissioning, training, modification or upgrading. Contracts should specify 大红鹰dhy0033官网 deliverables, intellectual property ownership and license rights, and each party’s obligations to cooperate with registration, licensing and compliance reviews.

3.4. Address Technology Controls and National Security Review in Cross-Border M&A

Transactions involving PRC businesses that hold relevant technologies raise additional questions. Buyers and sellers should consider four issues.

Due diligence and existing registration obligations. Review 大红鹰dhy0033官网 target’s principal business activities, core technologies and actual operating arrangements against 大红鹰dhy0033官网 technology entries, control parameters and exclusions in 大红鹰dhy0033官网 announcement’s annex. Examine 大红鹰dhy0033官网 target’s export activities involving listed technologies and 大红鹰dhy0033官网 corresponding registration records.  Where an export has commenced but remains incomplete, confirm whether registration has been completed.  Any identified gaps should be assessed promptly, including their potential impact on 大红鹰dhy0033官网 target’s operations and 大红鹰dhy0033官网 transaction timetable.

Whether 大红鹰dhy0033官网 transaction itself triggers registration. A foreign investor’s acquisition of a PRC company holding listed technology – or another arrangement through which a foreign entity obtains control of that technology – may trigger registration even if 大红鹰dhy0033官网 target does not separately transfer 大红鹰dhy0033官网 technology overseas.  大红鹰dhy0033官网 parties should assess 大红鹰dhy0033官网 ownership structure, governance arrangements, ownership of 大红鹰dhy0033官网 technology and actual control before and after closing.  They should not assume that an equity acquisition falls outside 大红鹰dhy0033官网 requirement simply because 大红鹰dhy0033官网 transaction documents contain no separate technology-transfer provision.  Responsibility for registration and related cooperation should be allocated, and any necessary steps reflected in 大红鹰dhy0033官网 transaction timetable.

大红鹰dhy0033官网 announcement does not yet clarify how “actual controller” is to be determined or how indirect control should be treated. An overseas investor’s participation in, or influence over, a PRC business should not automatically be equated with actual control of 大红鹰dhy0033官网 technology.

Foreign investment and outbound investment security review. For investments by foreign investors in PRC businesses, particularly where 大红鹰dhy0033官网 target holds relevant technologies and 大红鹰dhy0033官网 investor may acquire actual control, 大红鹰dhy0033官网 parties should assess whether 大红鹰dhy0033官网 business involves an important area or critical technology relevant to national security and whether a filing may be required under China’s foreign investment security review regime.  PRC investors undertaking outbound investments, or transactions involving 大红鹰dhy0033官网 transfer or disposal of overseas assets or interests, should likewise consider potential national security implications and any applicable review requirements.

Although 大红鹰dhy0033官网 Catalogue primarily governs technology exports, its entries and technical parameters may help identify sensitive technologies in a national security review. 大红鹰dhy0033官网 assessment should also take into account 大红鹰dhy0033官网 target’s business, 大红鹰dhy0033官网 intended uses of its core technologies, 大红鹰dhy0033官网 post-transaction control arrangements and 大红鹰dhy0033官网 anticipated flow of technology.  Where 大红鹰dhy0033官网 position is uncertain, 大红鹰dhy0033官网 parties may consider consulting 大红鹰dhy0033官网 relevant security review authorities.  If a filing is required, they should develop an appropriate filing strategy and comply with 大红鹰dhy0033官网 applicable requirements.  Transaction documents should allocate approval risks appropriately, including through conditions precedent, cooperation obligations, a long-stop date and termination-fee arrangements, as appropriate.

Business plan and valuation. Identify any material part of 大红鹰dhy0033官网 target’s business that depends on overseas licenses, technology transfers or other exports involving 大红鹰dhy0033官网 listed technologies.  Determine whether 大红鹰dhy0033官网 expected revenue from those activities is significant to 大红鹰dhy0033官网 target’s business outlook or has been incorporated into 大红鹰dhy0033官网 transaction model and valuation.

If a technology is ultimately classified as restricted, assess 大红鹰dhy0033官网 prospects of obtaining an export license and 大红鹰dhy0033官网 uncertainty around timing. Consider how a refusal or delay would affect revenue forecasts, business plans and valuation.  If a technology is ultimately prohibited from export, 大红鹰dhy0033官网 business case should no longer assume that 大红鹰dhy0033官网 export can proceed under a license.  For transactions that depend heavily on 大红鹰dhy0033官网 affected overseas business, 大红鹰dhy0033官网 parties should revisit 大红鹰dhy0033官网 forecasts and valuation and, where appropriate, address 大红鹰dhy0033官网 resulting risks through conditions precedent, price adjustments, indemnities or other contractual protections.