1260H CMC List (U.S. Department of Defense)

In August 2026, the “1260H CMC List (U.S. Department of Defense)” will be added to AEB's portfolio of restricted party lists. Should this list be relevant for your company, and you wish to include it into your AEB Compliance Screening software, the “1260H CMC List” can be licensed in addition to your already existing content.

What is the meaning of this list?

The 1260H CMC List (also known as the 1260H List) is an annually updated registry of Chinese military companies operating directly or indirectly in the United States – published in accordance with Section 1260H of the National Defence Authorisation Act (NDAA) for Fiscal Year 2021.

The Act defines a Chinese military company by reference to links to the Chinese People’s Liberation Army, the Chinese Ministry of State Security or the People’s Armed Police, and incorporates the concept of China’s “Military-Civil Fusion” strategy as a criterion. Entities involved in Military-Civil Fusion are defined in the Act as organisations that have one of several specified links to the government, such as “receiving support, operational guidance or political direction” from the Chinese government or the Communist Party of China.

The list itself does not impose any sanctions, export controls or transaction bans on the listed companies. This means that the inclusion of a company on this list alone does not automatically prohibit business with the listed Chinese company. Nevertheless, the listing may have important legal consequences. For example, restrictions may arise regarding a participation in contracts awarded by the US Department of Defense. In addition, inclusion on other sanctions or restricted party lists may follow, such as on the SDN List or a Non-SDN List. Classification as a “Military End-User” by the Bureau of Industry and Security (“BIS”) may also be possible, with resulting restrictions regarding items “subject to the EAR”. Reputational risks may also arise.

The original list (as of July 2026) can be found at the following link: https://media.defense.gov/2026/Jun/08/2003945537/-1/-1/1/ENTITIES-IDENTIFIED-AS-CHINESE-MILITARY-COMPANIES-OPERATING-IN-THE-UNITED-STATES-IN-ACCORDANCE-WITH-SECTION-1260H.PDF

Which companies should screen against the “1260H CMC List (U.S. Department of Defence)”?

Screening against this list is at the company’s discretion.

Do you need to license this list if you use third-party content in Compliance Screening?

If you screen your business partners against list content from third parties – such as Reguvis or Dow Jones – in your AEB Compliance Screening application, the “1260H CMC List” may already be included in your content. In that case you do not need to license this list separately/additionally. For more information, please contact your content provider.

Efficient restricted party list screening – the “1260H CMC List” and more: How can AEB help?

The AEB Compliance Screening Module takes care of list screening against the “1260H CMC List” and performs the screening automatically in the background – upon request also integrated into SAP®, Salesforce, Microsoft Dynamics 365, and other ERP and CRM systems. Please find an overview of AEB's available restricted party lists here.  

If you wish to include the “1260H CMC List” in your Compliance Screening, please request a non-binding quotation. Via the form, you can also contact a product expert.