Here’s something I haven’t seen written about elsewhere: Prior work at companies like Alibaba, Baidu, BYD, and DJI may now result in an F (student) or J (exchange visitor) visa denial.
On June 10, 2026, the U.S. Department of Defense (“DoD”) published an updated list of entities designated as “Chinese military companies.” DoD will not do business with listed companies. Most importantly for visa purposes, the list may lead to F (student) and J (exchange visitor) visa denials for applicants with ties to such companies.
The updated list of 188 companies includes, for example:
| Company: | Military-China Fusion Information: |
|---|---|
| 360 Security Technology, Inc. (Qihoo 360) | Qihoo 360 is a military civil fusion contributor to the Chinese defense industrial base because it is affiliated with the Ministry of Industry and Information Technology (MIIT) and with the Ministry of State Security (Sections 1260H(g)(3)(B)(i) and (g)(3)(B)(iv)). |
| Alibaba Group Holding Limited (Alibaba) | Alibaba is a military-civil fusion contributor to the Chinese defense industrial base because it is affiliated with MIIT (Section 1260H(g)(3)(B)(i)). |
| Autel Robotics Co., Ltd. (Autel Robotics) | Autel Robotics is a military-civil fusion contributor to the Chinese defense industrial base because it knowingly received assistance from the Government of China through science, technology, or industrial efforts initiated, granted, or created by, or provided under, or related to, the Chinese military planning apparatus or in furtherance of Chinese military industrial planning objectives through its designation as a “Little Giant” (Section 1260H(g)(3)(A)). |
| Baidu, Inc. (Baidu) | Baidu is a military-civil fusion contributor to the Chinese defense industrial base because it is affiliated with MIIT (Section 1260H(g)(3)(B)(i)). |
| BGI Group (and BGI Group subsidiaries: BGI Americas Corporation, BGI Genomics Co., Ltd. (BGI), Complete Genomics, Inc., Forensic Genomics International (FGI), GBI Diagnostics, Inc., Innomics, Inc., and STomics Americas, Ltd.) | BGI Group is directly with the PLA and indirectly affiliated with MIIT and the PLA (Section 1260H(g)(2)(B)(i)(I)). BGI Group is a military-civil fusion contributor to the Chinese defense industrial base because it knowingly received assistance from the Government of China through science, technology, research, and industrial efforts initiated, granted, or created by, or provided under, or related to the Chinese military planning apparatus, or in furtherance of Chinese military industrial planning objectives and because it is affiliated with MIIT and the PLA (Sections 1260H(g)(3)(A), (g)(3)(B)(i), and (g)(3)(B)(v)). |
| BYD Company Limited (BYD) | BYD is a military-civil fusion contributor to the Chinese defense industrial base because it is affiliated with MIIT and because it resides in or is affiliated with a military-civil fusion enterprise zone (Sections 1260H(g)(3)(B)(i) and (g)(3)(E)). |
| EVE Energy Co., Ltd. (EVE Energy) | EVE Energy is a military-civil fusion contributor to the Chinese defense industrial base because it knowingly received assistance from the Government of China through science, technology, research, or industrial efforts initiated, granted, or created by, or provided under, or related to, the Chinese military industrial planning apparatus, or in furtherance of Chinese military industrial planning objectives, through its selection as a “Single Champion” (Section 1260H(g)(3)(A)). |
| Inspur Group Co., Ltd. (Inspur) | Inspur is indirectly affiliated with MIIT and SASTIND (Section 1260H(g)(2)(B)(i)(I)). Inspur is a military-civil fusion contributor because it is affiliated with MIIT and SASAC (Sections 1260H(g)(3)(B)(i) and (g)(3)(B)(ii)). |
| Shenzhen DJI Technology Co., Ltd. (DJI) (and DJI subsidiary: Shenzhen Dajiang Baiwang Technology Co., Ltd.) | DJI is a military-civil fusion contributor to the Chinese defense industrial base because it knowingly received assistance from the Government of China through science, technology, research, and industrial efforts initiated, granted, or created by, or provided under, or related to, the Chinese military industrial planning apparatus, or in furtherance of Chinese military industrial planning objectives through multiple designations, such as a “Single Champion” designation; it is affiliated with MIIT, and it resides in or is affiliated with a military-civil fusion enterprise zone (Sections 1260H(g)(3)(A), (g)(3)(B)(i), and (g)(3)(E)). |
| Wuhan Geosun Navigation Technology Co., Ltd. (Geosun) | Geosun is indirectly affiliated with SASAC, SASTIND, and the PLA (Section 1260H(g)(2)(B)(i)(I)). Geosun is a military civil fusion contributor to the Chinese defense industrial base because it received a military production license (Section 1260H(g)(3)(F)). |
Alibaba has filed a lawsuit challenging its inclusion on the list.
President Trump issued Proclamation 10043 on the Suspension of Entry as Nonimmigrants of Certain Students and Researchers from the People’s Republic of China on May 29, 2020. The proclamation states that entry as an F (student) or J (exchange visitor), except for “undergraduate study,” is suspended and limited, if an individual has certain links to an entity that “implements or supports” China’s “military-civil fusion strategy.” Those links include:
- receiving funding;
- current or prior employment by;
- current or prior study at; or
- current or previous research conducted at or on behalf of such entity.
Certain exceptions apply. For more, see Update: Entry Suspended for Chinese Students and Researchers with Military-Civil Fusion Links – Chodorow Law Offices.
One of my initial criticisms of the proclamation was that it is vague about what counts as an “entity in the PRC that implements or supports, the PRC’s military-civil fusion strategy.” The DoD list now provides a bit more clarity.
Section 1260H of the William M. (Mac) Thornberry National Defense Authorization Act for Fiscal Year 2021 (the “1260H List” or the “CMC List”) 1260H requires DoD to publish this list at least annually. The list encompasses three categories of “Chinese military companies” doing business in the U.S.
- Category 1 -Direct or Indirect Connection to the Chinese Military: Entities directly or indirectly owned by, controlled by, or beneficially owned by, affiliated with, or in an official or unofficial capacity acting as an agent of or on behalf of, the People’s Liberation Army (“PLA”), Chinese military and paramilitary elements, security forces, police, law enforcement, border control, the People’s Armed Police, the Ministry of State Security (“MSS”), or any other organization subordinate to the Central Military Commission of the Chinese Communist Party, the Chinese Ministry of Industry and Information Technology (“MIIT”), the State-Owned Assets Supervision and Administration Commission of the State Council (“SASAC”), or the State Administration of Science, Technology, and Industry for National Defense (“SASTIND”).
- Category 2 – Contributors to China’s Military-Civil Fusion Strategy: Entities identified as pivotal to the integration of civilian and military advancements within China’s defense industrial base.
- Category 3 – Ownership Penetration: If an entity itself meets the definition of a “Chinese military company,” then its parent company or subsidiaries (if owning or being owned by the entity with ≥50% equity control) can also be deemed Chinese military companies.
Category 2, “military-civilian fusion contributors,” are defined by 1260H(d)(2) to include:
- Strategic Assistance: Entities knowingly receiving assistance from the Government of China or the Chinese Communist Party through science and technology efforts initiated under the Chinese military industrial planning apparatus.
- MIIT Affiliates: Entities affiliated with the Chinese Ministry of Industry and Information Technology, including research partnerships and projects.
- Recipients of SASTIND Assistance: Entities receiving assistance, operational direction or policy guidance from the State Administration for Science, Technology and Industry for National Defense.
- Defense Enterprises: Any entities or subsidiaries defined as a ‘‘defense enterprise’’ by the State Council of the People’s Republic of China.
- Enterprise Zones: Entities residing in or affiliated with a military-civil fusion enterprise zone or receiving assistance from the Government of China through such enterprise zone.
- Licencees for Military Production: Entities awarded with receipt of military production licenses by the Government of China, such as a Weapons and Equipment Research and Production Unit Classified Qualification Permit, Weapons and Equipment Research and Production Certificate, Weapons and Equipment Quality Management System Certificate, or Equipment Manufacturing Unit Qualification.
- Military Equipment Advertisers: Entities that advertise on national, provincial, and non-governmental military equipment procurement platforms in the People’s Republic of China.
- Other: Any other entities the Secretary determines is appropriate.
- Strategic Assistance: Organizations benefiting from Chinese government or Communist Party support through initiatives under the military industrial planning apparatus.
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