Fujian Jinhua

Fujian Jinhua Integrated Circuit is a Chinese state-backed DRAM manufacturer added to the United States Entity List in October 2018. Commerce cited risks to the long-term economic viability of United States suppliers of essential military components. A later criminal prosecution alleged trade-secret theft, but a federal judge found Jinhua not guilty after a bench trial in February 2024. The administrative listing and criminal judgment are distinct decisions under different standards.

The case

Jinhua was created in 2016 as a state-backed vehicle to develop an indigenous Chinese DRAM producer and partnered with Taiwan's UMC for process development. Micron alleged that former employees of its Taiwanese subsidiary carried its DRAM designs to UMC and on to Jinhua. In October 2018, Commerce stated that Jinhua's prospective additional production capacity, developed with United States-origin technology, threatened the long-term economic viability of US suppliers of essential military components. Commerce added Jinhua to the Entity List before its fabrication facility reached volume production. A Department of Justice indictment of Jinhua and UMC followed in November 2018. The controls severely constrained access to US equipment, but the cited public record does not establish permanent closure.

Unravelling of the predicate

UMC pleaded guilty in October 2020 to a trade-secret offence and paid a USD 60 million fine. On 27 February 2024, after a bench trial, United States District Judge Maxine Chesney found Fujian Jinhua not guilty on the charges tried against it. That judgment did not automatically remove the separate Entity List entry. As at 29 July 2026, this entry treats the export-control status as current only by reference to the consolidated official list and does not describe the company as destroyed.

Significance

Jinhua is cited from both directions. Control advocates treat it as evidence that export denial can interrupt a subsidised technology programme before scale. Critics emphasise that an administrative designation imposed before trial remained in force after an acquittal. The acquittal did not invalidate the Entity List decision because the criminal prosecution and export-control listing applied different legal standards and addressed different official findings. The episode therefore illustrates the importance of separating criminal proof, administrative risk assessment and industrial effect. Claims that the listing was principally industrial strategy, or that it permanently destroyed the firm, require evidence beyond the sources cited here.

See also

Micron · Entity List (15 CFR Part 744) · YMTC · SMIC · Bureau of Industry and Security (US Commerce) · Technology-embargo bundle · Chokepoint effect · Economic Kill Chain (EKC)

Sources

• United States Department of Commerce, Bureau of Industry and Security, Addition of an Entity to the Entity List, 83 FR 54519 (30 October 2018).
• United States Department of Justice, "PRC State-Owned Company, Taiwan Company and Three Individuals Charged with Economic Espionage" (1 November 2018), including the presumption-of-innocence notice.
• United States Department of Justice, "Taiwan Company Pleads Guilty to Trade Secret Theft in Criminal Case Involving PRC State-Owned Company" (28 October 2020).
• United States v Fujian Jinhua Integrated Circuit Co, No. 3:18-cr-00465, judgment of acquittal (ND Cal., 27 February 2024).
• United States Department of Commerce, Bureau of Industry and Security, Entity List, status checked 29 July 2026.