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The U.S. government’s campaign against Huawei Technologies (“Huawei”) represents a crucial battleground in the escalating U.S.-China rivalry for technological supremacy. While public attention largely focused on Huawei during President Trump’s trade war with China—particularly during the high-profile Meng Wanzhou case—U.S. military and intelligence services had been monitoring the company since its entry into the American market in the late 90s. This article chronicles the comprehensive history of U.S. government sanctions against Huawei.
Prelude
Early Congressional Investigation Reports
The Office of the Secretary of Defense’s annual reports to Congress on China’s Military Power first flagged Huawei in 2008, albeit in a minor subsection, noting the company’s close ties to the People’s Liberation Army (“PLA”).[1] While this initial reference was relatively understated compared to subsequent government actions, it marked the beginning of sustained U.S. government scrutiny aimed at containing Huawei’s expansion.
On October 8, 2012, the House Permanent Select Committee on Intelligence released a landmark report titled “Investigative Report on the U.S. National Security Issues Posed by Chinese Telecommunications Companies Huawei and ZTE.” [2] The investigation assessed whether these companies’ presence in U.S. markets risked compromising American critical infrastructure through potential loss of control. The report’s findings on Huawei were definitive: despite the company’s denials, it maintained close ties to both the Chinese Communist Party and military. The Committee also criticized Huawei’s failure to provide adequate information regarding potential sanctions and export control violations, particularly concerning Iran. Of special concern was Huawei’s growing integration into American telecommunications infrastructure, which the Committee viewed as a significant security threat. Based on these findings, the Committee issued two key recommendations: first, that the Committee on Foreign Investment in the United States (“CFIUS”) should block any “acquisitions, takeovers, or mergers” involving Huawei; and second, that American companies should cease purchasing telecommunications equipment from Huawei.
A subsequent White House-ordered review found no concrete evidence to support espionage allegations against Huawei.[3] However, the political momentum had already turned against the company. Major U.S. corporations, including tech giants Google and Intel, began distancing themselves from Huawei in line with the Committee's recommendations. Despite the increasingly hostile market conditions, the United States remained a strategic priority for Huawei, which continued to seek a significant presence in the American market.
Huawei’s U.S. Acquisition Efforts – Finish at the Start
Huawei’s attempts to enter the U.S. market faced early resistance from CFIUS. In 2008, CFIUS blocked a proposed investment by Bain Capital and Huawei to acquire 3Com, an American networking equipment manufacturer that had remained supportive of Huawei even during the contentious Huawei-Cisco IP lawsuit.[4] The proposed deal would have given Huawei only a 16.5% minority stake in 3Com, with an option to acquire an additional 5%.
Huawei also made three attempts to purchase American assets in 2010, which were all resisted by CFIUS. Various reports lightly mentioned that in around mid-2010, CFIUS blocked Huawei from purchasing the mobile wireless network division of Motorola, as well as 2Wire, an American supplier of broadband internet software.[5] Further details are unavailable despite the author’s diligence searches. Further, Huawei attempted to join deal to buy out United States telecommunications company SprintNextel, which was heavily opposed by members of Congress due to the belief that Huawei had ties to the Chinese military and presented a threat to U.S.’s key infrastructure.[6]
In another significant case, CFIUS ordered Huawei to unwind its May 2010 acquisition of assets from bankrupt U.S. virtualization firm 3Leaf Systems in February 2011. The transaction was particularly notable because Huawei had acquired only technology and key personnel for $2 million, without purchasing any equity interest or physical assets.[7] This unconventional structure led both companies to conclude that a CFIUS filing was unnecessary. The 3Leaf Systems case remains a remarkable example of CFIUS ordering divestiture for such a limited acquisition structure.
Following these setbacks, Huawei abandoned its acquisition strategy in the U.S. technology sector, opting instead to establish its own subsidiaries to enter the market. However, the company continued to be viewed as a significant national security threat, leading the U.S. government to systematically exclude it from high-value infrastructure contracts.[8]
Defense Sector Moves First
The first stringent restrictions on Huawei, like those imposed on other Chinese technology firms, targeted its presence in the U.S. defense sector. During a House Armed Services Committee hearing on June 22, 2016, Acting Assistant Secretary of Defense for Homeland Defense and Global Security Thomas Atkins gave an ambiguous response regarding the government’s knowledge of its own Huawei equipment usage.[9] The situation changed decisively with the National Defense Authorization Act for Fiscal Year 2018, enacted on December 12, 2017. This legislation explicitly prohibited the Secretary of Defense from procuring, obtaining, or renewing contracts for any systems using Huawei equipment or services as essential components.[10] Following this mandate, the Department of Defense implemented comprehensive screening measures to eliminate Huawei from its equipment network, including contract terminations, sales prohibitions, and usage restrictions wherever Huawei connections were identified.[11]
The Climax: Trump and the War Against Huawei
Administrative and Regulatory Actions
The campaign against Huawei intensified dramatically in 2018, two years into Donald Trump’s presidency. In April 2018, the Federal Communications Commission (“FCC”) took its first major step with a unanimous 5-0 preliminary vote on rules that would prohibit the use of government subsidies to purchase telecommunications equipment from companies deemed national security risks, including Huawei. The initiative culminated in November 2019 with a final order that specifically barred U.S. rural carriers from using government funds to purchase Huawei equipment, citing national security concerns.[12] Huawei’s subsequent protests and legal challenge against the FCC proved unsuccessful, with courts ultimately upholding the order.[13]
The restrictions on Huawei expanded significantly when President Trump signed the National Defense Authorization Act for Fiscal Year 2019 in August 2018. This legislation extended the ban on Huawei equipment beyond the Department of Defense to all federal agencies. The Act established three key prohibitions: federal agencies could not (1) procure systems using Huawei equipment or services as substantial or essential components, (2) contract with entities using Huawei equipment or services, or (3) allocate federal grants and loans for Huawei equipment.[14] While industry stakeholders later voiced concerns about implementation timelines and compliance challenges, these objections primarily focused on scheduling rather than substantively challenging the broader policy of excluding Huawei.
In March 2019, Huawei mounted a legal challenge against the U.S. government, arguing that the ban constituted a “bill of attainder”—legislation that inflicts punishment without the protections of a judicial trial or due process.[15] The District Court for Eastern Texas dismissed Huawei’s claim in February 2020, characterizing Congress’s legislation as a “prophylactic response” to national security threats posed by the company.[16] This decision was a landmark decision in the U.S. government’s favor that was subsequently used to support singling out TikTok and other foreign companies that are perceived to be a national threat to the U.S.
While Huawei’s legal challenge was still pending, President Trump escalated the pressure by issuing Executive Order 13873 (“EO 13873”) on May 15, 2019, titled “Securing the Information and Communications Technology and Services Supply Chain.”[17] This order authorized the U.S. government to restrict transactions with “foreign adversaries” involving information and communication technology. Simultaneously, the U.S. Department of Commerce placed Huawei and its affiliates on the Entity List. These actions significantly expanded the scope of restrictions, extending the Huawei equipment ban beyond federal agencies to encompass private sector transactions. The impact was immediate and severe: major U.S. technology companies, including Google and Qualcomm, severed their ties with Huawei. The ripple effects were evident in Huawei's financial performance, with the company reporting a 28% revenue decline in 2021 compared to 2020, particularly affecting its mobile phone business.
The Historic Export Controls on Huawei
The severity of U.S. export controls imposed on Huawei is unprecedented. The Bureau of Industry and Security (“BIS”) within the Commerce Department deployed its full arsenal of regulatory tools against the company, most notably the Entity List restrictions and the Foreign Direct Product Rule (“FDPR”).
The Entity List, administered by BIS under the Export Administration Regulations (EAR), is a regulatory mechanism that identifies specific foreign persons—including businesses, research institutions, and both government and private organizations—subject to specialized license requirements for export, reexport, and in-country transfer of designated items. Entities on this list face varying levels of licensing restrictions, with outcomes ranging from case-by-case review to presumption of denial. Huawei and its network of more than 150 affiliates face the strictest category: presumption of denial. This effectively prohibits any export, reexport, or transfer to Huawei entities without special license authorization. The BIS acknowledged the complexity of existing Huawei deployments, particularly in rural telecommunications networks, by creating a specific exemption. This “cybersecurity research and vulnerability disclosure exception” permits telecommunications providers to share security vulnerability information with Huawei for maintaining existing network equipment.[18]
The Entity List designation proved to be just the beginning. On May 15, 2020, BIS escalated restrictions by implementing an immediate amendment to the FDPR.[19] This rule historically regulated foreign products derived from U.S.-origin technology or software in limited, specific circumstances. Three months later, BIS dramatically expanded the final rule’s scope, creating what became known as the “Huawei FDPR.” The expanded rule captured any products that either: (1) were destined for eventual Huawei use, regardless of direct delivery, or (2) involved Huawei as a party to the transaction in any capacity.[20] BIS further tightened the pressure in December 2020 by adding the Semiconductor Manufacturing International Corporation (“SMIC”), a crucial Huawei supplier, to the Entity List. This move signaled a broader strategy to separate the entire Chinese semiconductor industry from U.S. technology and markets.
Note that during this period, Huawei retained access to the U.S. consumer market—the Entity List restrictions did not affect imports of Huawei products into the United States. However, a significant limitation emerged: users could not return devices to Huawei or its listed affiliates for repairs without obtaining a BIS license.[21]
Specific License as a “Backdoor”
Despite the Entity List’s apparent blanket prohibition on U.S. companies selling to Huawei, major technology firms like Intel and Qualcomm initially secured special licenses to maintain their chip revenue streams from the company. However, this arrangement ended abruptly in May 2024 following Huawei's release of its first AI-enabled laptop, the MateBook X Pro, featuring Intel’s new Core Ultra 9 processor. The launch triggered the revocation of these special licenses.[22]
In U.S. export controls and sanctions, regulators employ a dual licensing system: general licenses and specific licenses. General licenses provide broad authorizations that permit the export of designated items to specified destinations without requiring individual transaction approvals. In contrast, specific licenses are individual authorizations tailored to particular export transactions, detailing the exact exporter, item, destination, and end-user. While general licenses are public documents accessible to all, specific licenses remain confidential under Section 1761(h) of the Export Control Reform Act of 2018. This confidentiality, combined with their individualized nature, makes specific licenses potentially susceptible to external influence.
The economic impact of Huawei's Entity List designation proved far-reaching, creating ripple effects throughout the technology supply chain. While the restrictions severely impacted Huawei, they also dealt a significant blow to more than 30 U.S. suppliers dependent on Huawei’s business. According to Goldman Sachs analysis cited in a January 2022 Congressional Research Service (“CRS”) report,[23]U.S. companies faced potential revenue losses totaling $105 billion (See Figure 1 below).
The implementation of such a sweeping regulation understandably raised industry-wide concerns. Following Huawei’s addition to the Entity List in May 2019, BIS promptly issued a temporary general license (“TGL”). This license allowed U.S. companies to continue providing certain products and services to Huawei for a limited time, and was subsequently extended five times before its final expiration.[24] In response to these restrictions, the Semiconductor Industry Association (“SIA”) of the United States reportedly met with the Commerce and Treasury Secretaries. Their aim was to convey that these limitations would adversely affect the U.S. semiconductor industry by restricting access to its largest market.[25] Concurrent with the SIA’s lobbying efforts, numerous U.S. companies submitted specific license applications, seeking permission to continue selling products to Huawei.
In October 2021, the House Committee on Foreign Affairs expressed concern over the executive branch’s apparent leniency in granting specific licenses to Huawei and SMIC. Consequently, they requested data from BIS. The BIS submission revealed that between November 9, 2020, and April 20, 2021, 169 license applications related to Huawei were considered, and 113 applications (69.3%) were approved, totaling USD 61,432,330,663 in value. 48 applications were returned without action, and only 2 applications were denied. [26] It’s worth noting that data outside this specific period remains unavailable to the public.
While the identities of license applicants remain confidential, recent news reports suggest that technology giants Intel and Qualcomm have significantly benefited from the specific license regime. Their licenses were reportedly only revoked in May 2024. [27] This timeline indicates that Intel and Qualcomm likely gained a substantial competitive advantage over other U.S. firms that did not request specific licenses for sales to Huawei. This advantage spanned approximately five years, beginning when Huawei was added to the Entity List.
The Meng Wanzhou Saga
The arrest of Meng Wanzhou, daughter of Huawei founder Ren Zhengfei, garnered unprecedented global media attention. On December 1, 2018, at the request of the United States, the Royal Canadian Mounted Police (“RCMP”) apprehended Meng during her layover in Vancouver. She was en route to Mexico from Hong Kong when the arrest occurred. The warrant for Meng’s arrest, issued by the Eastern District of New York, cited charges of bank fraud, wire fraud, and conspiracy to commit both offenses. U.S. authorities alleged that Meng had misled financial institutions regarding Huawei’s relationship with Skycom, a company operating in Iran. This deception potentially violated U.S. sanctions against Iran.
On January 29, 2019, the U.S. government filed a formal extradition request for Meng Wanzhou. A crucial point of contention in the extradition proceedings was whether Meng’s case satisfied Canada’s “double criminality” standard, given that Canada does not maintain sanctions against Iran. The U.S. government’s argument centered on two key points: (1) Meng committed fraud by misrepresenting Huawei’s business dealings in Iran to banks, primarily HSBC Holdings plc.; and (2) this misrepresentation put these banks at risk of violating U.S. sanctions and facing penalties. The Canadian court ultimately ruled that the alleged fraud met the double criminality test. This decision was based on the interpretation that fraud is a crime in Canada, regardless of the specific context of sanctions.
Despite the apparent legality of the proceedings, numerous reports from both China and international sources have suggested that Meng’s arrest was politically motivated. Notably, two key figures were reportedly briefed about Meng’s impending arrest: John Bolton, then U.S. National Security Adviser and known for his hawkish stance on China; and Justin Trudeau, Prime Minister of Canada. These reports allege that both Bolton and Trudeau effectively “greenlighted” the arrest, raising questions about the political dimensions of the case. [28]
The U.S. government frequently pursues criminal charges against foreign entities for potentially “causing” U.S. financial institutions to process payments to sanctioned jurisdictions and entities. This practice is based on two key factors: (1) the clearance of U.S. dollars must go through U.S. correspondent banks; and (2) any foreign entity using U.S. dollars in transactions with sanctioned persons is considered to be violating U.S. sanctions. This far-reaching application of U.S. sanctions law has led many countries to pursue de-dollarization strategies, seeking to reduce their dependence on the U.S. dollar in international transactions.
Meng Wanzhou’s case concluded with a Deferred Prosecution Agreement (“DPA”) with U.S. prosecutors, an outcome considered extremely rare for this type of case handled by the U.S. Department of Justice. The resolution involved significant political efforts behind the scenes. In the resolution, Meng had to admit to some alleged wrongdoing as stipulated facts to obtain the DPA, and despite the admission, the agreement allowed Meng to return to China. This unusual resolution highlights the complex interplay of legal proceedings and diplomatic negotiations in high-profile international cases.
Pressure on Allies to Boycott Huawei
The Trump administration also required, and in many cases, coerced countries to take actions against Huawei. All the five-eye countries took actions against Huawei in one way or another, ranging from a complete 5G network ban to specific transaction blocking. Australia, the United Kingdom, and Canada all announced ban on Huawei equipment in their 5G network, citing national security concerns.[29] Sweden followed suit (but likely more out of the interest to protect Ericsson).[30] Japan and India also excluded Huawei from being their 5G network partners.[31]
Biden Agrees with Trump – Huawei Continues to be Under Pressure
Despite Huawei’s hopes for policy changes, the Biden administration, which took on January 20, 2021, maintained and expanded the restrictive measures against the company. The administration extended most, if not all, of the Trump-era restrictive actions. It also laid down a landmark export control case Seagate (further described below). This continuation and expansion of policies demonstrate a bipartisan approach in the U.S. government’s stance towards Huawei, transcending changes in administration.
Administrative and Regulatory Actions
On May 15, 2021, President Biden renewed Executive Order 13873, maintaining restrictions that prevent U.S. companies from using Huawei and ZTE equipment due to national security concerns. [32] The following month, he signed Executive Order 14032, which expanded upon Trump-era Executive Order 13959. This expanded order prohibits U.S. investors from purchasing or investing in securities of companies designated as “Communist Chinese Military Companies” by the U.S. government, a designation that includes Huawei. [33]
Congressional efforts to restrict Huawei's operations have continued. In January 2023, two members of the House of Representatives introduced the "Keep Huawei on the Entity List Act." This proposed legislation would prevent the Secretary of Commerce from either removing Huawei and its affiliates from the Entity List or modifying existing licensing policies. [34] While the bill was referred to the House Committee on Foreign Affairs, it has not progressed further as of this writing.[35]
Following the Huawei FDPR, the U.S. government expanded its use of this regulatory tool to target other countries of concern, including Russia, Belarus, and China. In October 2022, BIS implemented two additional foreign direct product rules: the Advanced Computing FDP Rule and the Supercomputer FDP Rule. These regulations aim to restrict China’s access to and production of advanced computing technologies. As a result, companies like ASML are now prohibited from exporting their most advanced extreme ultraviolet (EUV) lithography machines to China, along with any chips produced using this equipment.[36]
More recently, the House Select Committee on the Chinese Communist Party called on the Department of Commerce to address potential sanctions circumvention by Huawei, citing concerns about the company’s alleged development of “clandestine semiconductor facilities.”[37] The Committee specifically identified three companies—Pengxinxu, SwaySure, and Qingdao SiEn—as part of what they describe as Huawei's “clandestine chip network,” and urged their addition to the Entity List. This action demonstrates the U.S. government's ongoing commitment to closing what it perceives as regulatory loopholes that could enable Huawei's continued growth.
Strong Enforcement: The Seagate Case et al.
Among U.S. companies affected by the unprecedented trade restrictions on Huawei, Seagate Technology LLC, a California-based hard disk drive (HDD) manufacturer, stood out for its particularly bold response. Following the implementation of the Huawei FDPR, Seagate publicly declared its intention to maintain business relations with Huawei, even signing a three-year Strategic Cooperation Agreement with the Chinese company. This decision quickly drew scrutiny from BIS. The consequences were significant. On April 19, 2023, the BIS levied a $300 million penalty against Seagate for violating the Huawei FDPR through continued shipments—the largest standalone administrative penalty in BIS history. [38] Through this unprecedented fine, the BIS sent an unequivocal message: companies violating the Huawei FDPR would face severe consequences.
Stakeholders in the semiconductor industry continues to be alarmed by the Huawei FDPR. Most recently in October 2024, Taiwan Semiconductor Manufacturing Co. (“TSMC”) suspended shipments to a customer after discovering that one of its chips had been incorporated into a Huawei product, violating both Taiwanese and U.S. export control regulations. The situation came to light when technology research firm TechInsights disassembled Huawei's Qingyun L540 laptop and identified that its HiSilicon Kirin 9006C processor was manufactured by TSMC.[39] TSMC reported the alleged violation to Taiwan and U.S. authorities and an investigation is reportedly underway.
Proactive Government Subsidies
The Biden administration has taken a different approach from its predecessor by prioritizing the development of domestic telecommunications infrastructure capabilities. A significant step in this direction came on August 9, 2022, when President Biden signed the CHIPS and Science Act into law. This legislation authorized approximately $280 billion in new funding to strengthen domestic research and manufacturing of advanced technologies, with a particular focus on the semiconductor sector. [40] In a more targeted effort to counter Huawei’s influence, the National Telecommunications and Information Administration (“NTIA”) announced a $420 million grant program in May 2024. This strategic initiative aims to foster competition against Huawei’s dominance in network equipment. The program is distinctive in its approach, extending eligibility to companies from both the United States and allied nations, while requiring grant recipients to collaborate with network operators to ensure their products’ commercial viability. [41]
Prospect and Future
Despite all these challenges launched by the U.S. government, Huawei has demonstrated remarkable resilience in the face of extensive U.S. sanctions and global restrictions. Despite initial setbacks, particularly in its smartphone business, the company has adapted and thrived through several key strategies. These include intensifying research and development efforts, diversifying into new business areas like cloud services and electric vehicles, and leveraging strong support from the Chinese domestic market. Huawei has also worked to develop indigenous alternatives to U.S. technology, including its own operating system (HarmonyOS) and chip designs. Although challenges persist, particularly in accessing cutting-edge semiconductor technology, Huawei’s ability to innovate, its long-term planning approach, and the backing of the Chinese market have allowed it to not only survive but in many ways emerge stronger. This is evidenced by Nvidia’s most recent announcement naming Huawei as a competitor in four out of five major categories of its business, including GPUs, which are currently widely used in generative artificial intelligence.[42] We will see how Huawei continues to navigate the strictest sanctions ever imposed on a company by the U.S. government.
[1] All reports that are indicated as “archived” are not currently unretrievable online; please contact us if you would like to obtain an electronic copy of these reports.
[3] http://www.reuters.com/article/2012/10/18/us-huawei-spying-idUSBRE89G1Q920121018
[4] https://www.forbes.com/2008/03/20/3com-bain-cfius-markets-equity-cx_cg_0320markets30.html
[5] https://www.globaltimes.cn/content/625736.shtml
[6] Amrietha Nellan, AVIC International a Success: How Regulatory Changes to CFIUS Has Limited Political Interference and Empowered Chinese Investors to Obtain a Successful Review, Hastings Business Law Journal, Volume 9, Number 3 Spring 2013.
[7] https://www.lexology.com/library/detail.aspx?g=5efa9584-d1d3-425a-9934-ba81e3170571
[8] https://phys.org/news/2010-11-sprint-axes-china-huawei-zte.html
[9] Thomas Atkins’ original language was “[t]he fact that a product does not appear on an APL [Approved Products List] does not mean contractors cannot offer bids or that the government can still select outside the APL. Short of suspension and debarment, federal contractors and vendors are not precluded from competing on DOD contracts.” See U.S. Congress, House Committee on Armed Services, Military Cyber Operations, 114th Cong., 2nd sess., June 22, 2016, H.A.S.C. No. 114-128.
[10] .L. 115-91, Title XVI, Subtitle D, §1656.
[11] https://www.wsj.com/articles/pentagon-asking-military-bases-to-remove-huawei-zte-phones-1525262076; https://www.armed-services.senate.gov/hearings/18-04-26-department-of-defense-budget-posture
[14] P.L. 115-232. The Bill of Attainder Clause in the U.S. Constitution provides that “No Bill of Attainder or ex post facto Law shall be passed” (Article I, Section 9, Clause 3). A bill attainder is “a legislative act which inflicts punishment without a judicial trial.”
[15] Huawei Technologies USA, Inc., et al. v. The United States of America, et al., District Court for Eastern Texas, 2019.
[16] Ibid.
[18] Footnote 2 of the Entity List provides that “[t]he following exports, exports, and transfers (in-country) to Huawei Technologies Co., Ltd. (Huawei) and its non-U.S. affiliates on the Entity List for cybersecurity research and vulnerability disclosure subject to other provisions of the EAR are excluded from the Entity List license requirements: when the disclosure to Huawei and/or to its listed non-U.S. affiliates is limited to information regarding security vulnerabilities in items owned, possessed, or controlled by Huawei or any of its non-U.S. affiliates when related to the process of providing ongoing security research critical to maintaining the integrity and reliability of existing and currently ‘fully operational network’ and equipment. A ‘fully operational network’ refers to a ‘third party’ network providing services to the ‘third party’s’ customers. The term ‘third party’ refers to a party that is not Huawei, one of its listed non-U.S. affiliates, or the exporter, reexporter, or transferor, but rather an organization such as a telecommunications service provider.”
[19] FDPR essentially allows BIS to regulate foreign products that are “direct product” of U.S.-origin technology or software when they are exported or transferred to certain countries. The application of FDPR has been historically rare and limited to special circumstances, such as with respect to two previous military items 9*515 (foreign-made spacecraft-related items) and 600 series (certain military items).
[21] https://www.bis.doc.gov/index.php/documents/pdfs/2447-huawei-entity-listing-faqs/file
[22] https://www.aljazeera.com/economy/2024/5/8/us-cancels-export-licenses-of-suppliers-to-chinas-huawei
[23] https://crsreports.congress.gov/product/pdf/R/R47012/2
[24] On August 21, 2019, BIS published an extension of the TGL that extended its validity another 90 days, through November 18, 2019. BIS then extended the TGL for another 90 days through February 16, 2020, and then again through April 1, 2020, then May 15, 2020, and then through August 13, 2020, when the TGL expired.
[25] https://www.reuters.com/article/world/us-chipmakers-quietly-lobby-to-ease-huawei-ban-idUSKCN1TH0V8/
[26] https://foreignaffairs.house.gov/wp-content/uploads/2021/10/Huawei-Licensing-Information.pdf
[27] https://www.reuters.com/technology/us-revoked-some-export-licenses-chinas-huawei-2024-05-07/
[29] https://www.iiss.org/publications/strategic-comments/2019/australia-huawei-and-5g/; https://www.gov.uk/government/news/huawei-legal-notices-issued; https://www.bbc.com/news/business-61517729
[31] https://www.washingtonpost.com/world/asia_pacific/japan-effectively-bans-chinas-huawei-zte-from-government-contracts-joining-us/2018/12/10/748fe98a-fc69-11e8-ba87-8c7facdf6739_story.html; https://www.bbc.com/news/business-56990236
[32] https://therecord.media/biden-extends-telecom-executive-order-huawei-zte-china
[34] https://www.congress.gov/bill/118th-congress/house-bill/686/text
[35] https://www.congress.gov/bill/118th-congress/house-bill/686/all-info
[36] https://www.learnexportcompliance.com/understanding-the-foreign-direct-product-rule/
[39] https://www.techinsights.com/blog/huawei-qingyun-l540-laptop-hisilicon-9006c-manufactured-tsmc
[40] https://en.wikipedia.org/wiki/CHIPS_and_Science_Act
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