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“Encryption technologies with encryption strength exceeding the specified threshold can no longer be freely transferred to a Chinese party.”

Tina Li and Frank Pansanctionsnews.bakermckenzie.com ↗

China now needs a license before strong encryption technology can be transferred in. It took effect the day it was announced. Two arms of the commerce ministry will police it under two different schemes, and the lawyers can’t yet say whether software counts. The ambiguity is the point. Every foreign company now operates at the state’s discretion.