On August 28, 2020, China released an updated Catalogue of Prohibited and Restricted Export Technology (中国禁止出口限制出口技术目录) (the “Export Restrictions Catalogue”).[1] The updated Export Restrictions Catalogue includes several new items, two of which might impose a requirement for ByteDance (字节跳动), owner of the popular short video-sharing mobile application TikTok, toobtain an export license from theappropriate provincial office of China’sMinistry of Commerce (商务部) (the “MOC”) in order to sell TikTok’s U.S. operations. The recent announcement that Microsoft Corp. lost to Oracle Corp. in the bidding war for TikTok’s U.S. operations, and that the Oracle deal might not involve an outright sale of those operations,[2] suggests that in releasing the new Export Restrictions Catalogue, Beijing might have effectively blocked the Microsoft deal.
