China’s Dual-Use Export Controls

China’s Dual-Use Export Controls: The Criminalization Threshold

From Administrative Penalties to Criminal Cases: The Fuji Electric Group Employee Arrest and Prior Cases

Special Intelligence Brief

Criminal-risk analysisCase-level evidenceSource-traceableInformation cutoff: 27 August 2026

China’s Dual-Use Export Controls: The Criminalization Threshold cover

Research Overview

This Special Intelligence Brief is a re-edited standalone version of the analysis of the Fuji Electric Group employee arrest case and comparisons with China’s published judicial record contained in WTS Institute’s Japan-Bound Trade Edition 2026. It focuses on the criminal-proceedings track that differs from the 20 Japan-bound administrative enforcement cases, and organizes earlier cases involving foreign nationals, published criminal judgments, factors that may affect sentencing, and forward indicators to monitor.

20 casesCompared with the Japan-bound administrative track

6 judgmentsPublished criminal / peripheral comparator cases

4 scenariosConditional pathways from no prosecution to 5+ years

Questions This Brief Addresses

Why is the present matter on a different legal track from the 20 Japan-bound administrative enforcement cases?
Are there prior cases in which foreign nationals were held criminally liable for DU-related smuggling offenses?
What factors in published criminal judgments may affect criminal liability and sentencing?
What can and cannot currently be said about the Fuji Electric-related case?
Which indicators matter most for assessing how the case develops?

Evidence Base

Japan-bound 20

Compares the present case with 20 Japan-bound administrative enforcement cases.

CR-01–CR-06

Five DU-related criminal cases plus one peripheral comparator.

Foreign national

Examines an earlier case involving imprisonment and deportation of a foreign national.

Scenario-based

Uses conditional scenarios while explicitly bounding what public information can support.

Core Structure

Chronology of the Fuji Electric Group employee arrest case

Suspected criminal offense

Shift from administrative enforcement to criminal prosecution

Earlier foreign-national case (the “9·12” case)

Case profiles of six published/related judgments

Factors that may affect sentencing

What can and cannot be said

Four possible future scenarios and qualitative confidence

Indicators to monitor

Institutional Pricing

Standard Institutional License for internal use within one purchasing legal entity or institution. Japanese and English editions are included where available.

Standard Institutional License

USD 5,000

Upgrade credit: If the same purchasing legal entity later acquires China’s Dual-Use Export Controls | Japan-Bound Trade Edition 2026 (USD 15,000), the USD 5,000 paid for this brief will be credited in full, leaving USD 10,000 due. Please contact WTS Institute before submitting the later purchase so the credit can be applied.

Standard Institutional License for internal use within one purchasing legal entity or institution. Japanese and English editions are included where available.

Proceed to Standard License Purchase

This report is based on public information and does not determine that any party engaged in unlawful conduct. The identification of the individuals as Fuji Electric group employees, the timing of formal arrest, the goods at issue and specific alleged conduct rely in part on source-based reporting by Japanese news organizations. Key facts—including quantity, value, number of exports, intent and prosecution status—remain insufficiently public, and the report does not predict a specific sentence.

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