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Sanctioned Surveillance Firms and the Western Companies Still Supplying Them

Which surveillance and spyware firms the US has blacklisted, what each sanction restricts, and documented Western cloud, retail, app and investment ties.

Sanctioned Surveillance Firms and the Western Companies Still Supplying Them

Key Findings

  • On October 9, 2019, the US added eight Chinese surveillance and AI firms, including Hikvision, Dahua, SenseTime, Megvii and iFlytek, to the Entity List over the treatment of Uyghurs in Xinjiang.
  • Spyware makers NSO Group and Candiru were added to the Entity List on November 4, 2021; four Intellexa and Cytrox entities followed on July 18, 2023, and OFAC blocked Intellexa-linked people and companies in March and September 2024.
  • IPVM reported in September 2022 that Amazon Web Services hosted Hikvision and Dahua cloud platforms, including Hik-Connect, and that Amazon ran storefronts for relabeled brands linked to both firms.
  • Hikvision's Hik-Connect app was still listed on Google Play with more than 50 million downloads when we checked on October 1, 2026.
  • The Predator Files investigation found Intellexa alliance products in at least 25 countries, including EU members Austria and Germany.

The US government has blacklisted the world’s best-known surveillance companies, from Chinese camera and facial recognition makers such as Hikvision, Dahua and SenseTime to spyware vendors NSO Group, Candiru and Intellexa. But each sanction tool restricts something different, and none of them cuts a company off from Western technology entirely. Investigations have documented Western cloud hosting, retail distribution, app-store availability and investment that continued to reach some of these firms after they were listed.

Main US actions against surveillance firms

CompanyBased inUS actionDateSource
HikvisionChinaEntity List; investment ban (EO 14032 annex)Oct 9, 2019; Jun 3, 2021Federal Register, 2019; Federal Register, 2021
DahuaChinaEntity ListOct 9, 2019Federal Register, 2019
SenseTimeChinaEntity List; investment ban (NS-CMIC)Oct 9, 2019; Dec 10, 2021Federal Register, 2019; Treasury, 2021
MegviiChinaEntity List; investment ban (NS-CMIC)Oct 9, 2019; Dec 16, 2021Federal Register, 2019; Treasury, 2021
iFlytekChinaEntity ListOct 9, 2019Federal Register, 2019
Yitu, Xiamen Meiya PicoChinaEntity List; investment ban (NS-CMIC)Oct 9, 2019; Dec 16, 2021Federal Register, 2019; Treasury, 2021
CloudWalk, NetPosa, Leon TechnologyChinaInvestment ban (NS-CMIC)Dec 16, 2021Treasury, 2021
NSO GroupIsraelEntity ListNov 4, 2021Federal Register, 2021
CandiruIsraelEntity ListNov 4, 2021Federal Register, 2021
Intellexa S.A., Intellexa Ltd, Cytrox AD, Cytrox HoldingsGreece, Ireland, North Macedonia, HungaryEntity ListJul 18, 2023Federal Register, 2023
Intellexa consortium (founder Tal Dilian, related people and companies)VariousOFAC SDN sanctions (asset blocking)Mar 5, 2024; Sep 16, 2024Federal Register, 2024; Treasury, 2024

The reasons differ by group. The 2019 Chinese listings cited involvement in human rights abuses in China’s campaign against Uyghurs and other Muslim minorities in Xinjiang (Federal Register, 2019). Treasury said a SenseTime subsidiary had developed facial recognition that could determine a target’s ethnicity, with a focus on Uyghurs (Treasury, 2021). For NSO Group and Candiru, Commerce found they supplied spyware to foreign governments that used it to target officials, journalists, activists, academics and embassy staff (Federal Register, 2021).

What each sanction restricts

News coverage uses “sanctioned” loosely, but the four main US tools work very differently:

ToolAdministered byWhat it doesWhat it does not doSource
Entity ListCommerce (BIS)Requires a license to export, reexport or transfer US-regulated items to the company; these listings carry a presumption of denialDoes not freeze assets or ban buying the company’s productsFederal Register, 2021
NS-CMIC listTreasury (OFAC)Bars US persons from buying or selling the company’s publicly traded securitiesDoes not restrict trade in goodsTreasury, 2021
SDN listTreasury (OFAC)Blocks property under US jurisdiction; US persons generally may not deal with the listed partyApplies only to named persons and entitiesFederal Register, 2024
FCC Covered ListFCCBlocks new US equipment authorizations for covered gearDoes not ban owning existing devicesD.C. Circuit, 2024

These differences explain how Western companies can still deal with listed firms. Most Chinese surveillance firms are on the Entity List rather than the SDN list, so US companies need a license to send them regulated technology, but buying their cameras, hosting their apps or serving their customers is not automatically prohibited. Among the firms covered here, only the Intellexa consortium faces full SDN asset blocking.

Documented Western ties after listing

None of these cases, as reported, involved a court finding that a Western company broke sanctions law.

Western company or channelSanctioned firmWhat was documentedSource
Amazon Web ServicesHikvision, DahuaAWS hosted cloud platforms including Hik-Connect and HikCentral (Sept 2022)IPVM, 2022
Amazon marketplaceHikvision, DahuaStorefronts for EZVIZ (Hikvision subsidiary), Lorex (then a Dahua subsidiary) and Amcrest (a Dahua relabeler)IPVM, 2022
US federal procurement (GSA Advantage)Hikvision, DahuaRelabeled products bought by agencies including the Army, Navy, Air Force, State Department and VA despite the NDAA ban (2021)IPVM, 2021
Google PlayHikvisionHik-Connect app listed with 50 million+ downloads (checked Oct 1, 2026)Google Play, 2026
US investorsNSO GroupInvestor group led by US film producer Robert Simonds acquired controlling ownership (Oct 2025)TechCrunch, 2025
EU-based companies and EU customersIntellexa allianceAlliance products found in at least 25 countries, including Austria, Germany and Switzerland; France-based Nexa companies were part of the allianceAmnesty International, 2023

Amazon’s cloud and retail ties

IPVM’s 2022 investigation found that Amazon’s cloud division ran backend infrastructure for Hikvision and Dahua remote-viewing platforms, while its marketplace sold the companies’ products under other brand names (IPVM, 2022). Amazon told IPVM it complies with applicable laws, including Section 889 of the 2019 NDAA. Senator Marco Rubio responded by calling for an investigation. IPVM’s report is a snapshot from 2022; we could not verify whether these arrangements have changed since.

Relabeling and government buyers

White labeling can hide a sanctioned manufacturer even from government purchasing systems. A year before the Amazon report, IPVM traced Hikvision and Dahua products sold through the GSA Advantage portal under other brands to federal buyers, despite the procurement ban. Contractors said they had been misled by distributors, and GSA said it relied on contractor certifications and was improving checks (IPVM, 2021).

App stores

Entity List rules govern exports to the listed companies; they do not by themselves stop consumers from downloading a listed company’s software. When we checked on October 1, 2026, Hikvision’s Hik-Connect consumer app was still listed on Google Play with more than 50 million downloads (Google Play, 2026). We did not test the app’s data flows.

Western ties to spyware vendors

Spyware shows the most direct Western involvement. Intellexa was set up as an EU-based alliance, and the 2023 Predator Files investigation by Amnesty International and the European Investigative Collaborations network concluded that European states had failed to regulate the trade (Amnesty International, 2023). Treasury says Predator can infect devices through one-click and zero-click attacks and give operators access to messages, photos, location and microphone recordings (Treasury, 2024).

NSO Group, still on the Entity List, came under US majority ownership in October 2025. The company said its headquarters and core operations remain in Israel (TechCrunch, 2025). As of our check of the Federal Register on October 1, 2026, we found no notice removing NSO Group from the Entity List.

Western tech firms have also exposed and fought spyware vendors. Microsoft and Citizen Lab exposed Candiru in 2021, and Microsoft patched two Windows zero-days the company had exploited; Microsoft counted at least 100 victims in countries including Spain and the UK (Citizen Lab, 2021). In WhatsApp’s lawsuit against NSO, a US jury awarded more than $167 million in 2025; the judge later cut damages to about $4 million but permanently barred NSO from targeting WhatsApp (TechCrunch, 2025).

What this means for you

  • Check who really made your camera. Relabeled Hikvision and Dahua products have been sold under other brands, and firmware pages, FCC IDs and companion apps often reveal the original manufacturer.
  • Know what a companion app connects to. A camera’s app and cloud service decide where your footage goes, so prefer local recording if you are uncomfortable with a vendor’s cloud.
  • Keep phones and computers updated. Candiru’s attacks relied on Windows zero-days that Microsoft later patched, and Predator uses one-click and zero-click exploits; installing security updates promptly closes known holes.
  • If you invest, note that US persons cannot buy securities of NS-CMIC-listed companies, and check fund holdings if this matters to you.
  • Most listed surveillance firms still sell worldwide, so “sanctioned” does not mean “gone.” The sanctions mainly limit what Americans can sell them or invest in.

Methodology

The sanctions table is based on Federal Register documents (retrieved from govinfo.gov) and US Treasury press releases; we also checked the Federal Register for later removal notices for NSO Group and Intellexa entities. Evidence of Western ties comes from IPVM investigations, Amnesty International’s Predator Files work, Citizen Lab, TechCrunch and our own check of a Google Play listing on October 1, 2026.

Sanctions lists change, so confirm current status on the official Commerce and OFAC lists. Reports that some Intellexa-linked individuals were later delisted could not be confirmed from an official source during our research, so only designations are reported here. The investigations cited are snapshots in time, and the companies named may have changed practices since. Allegations about chip or component supply that we could not verify from an accessible primary or investigative source are left out. Inclusion of a company here does not imply it violated any law.

Sources

  1. Addition of Certain Entities to the Entity List (doc. 2019-22210) — Federal Register / Bureau of Industry and Security, 2019-10-09
  2. Addition of Certain Entities to the Entity List (doc. 2021-24123) — Federal Register / Bureau of Industry and Security, 2021-11-04
  3. Additions to the Entity List (doc. 2023-15343) — Federal Register / Bureau of Industry and Security, 2023-07-19
  4. Notice of OFAC Sanctions Action (doc. 2024-05045) — Federal Register / Office of Foreign Assets Control, 2024-03-11
  5. Treasury Sanctions Enablers of the Intellexa Commercial Spyware Consortium — US Department of the Treasury, 2024-09-16
  6. Executive Order 14032 (Annex) — Federal Register, 2021-06-07
  7. Treasury Sanctions Perpetrators of Serious Human Rights Abuse on International Human Rights Day — US Department of the Treasury, 2021-12-10
  8. Treasury Identifies Eight Chinese Tech Firms as Part of the Chinese Military-Industrial Complex — US Department of the Treasury, 2021-12-16
  9. Amazon Powers Dahua and Hikvision Sales and Cloud Services — IPVM, 2022-09-26
  10. Feds Buy Banned Chinese Equipment via GSA — IPVM, 2021-07-20
  11. Hik-Connect - for End User (Google Play listing) — Google Play, 2026-10-01
  12. Global: 'Predator Files' investigation reveals catastrophic failure to regulate surveillance trade — Amnesty International, 2023-10-05
  13. Hooking Candiru: Another Mercenary Spyware Vendor Comes into Focus — Citizen Lab, 2021-07-15
  14. Spyware maker NSO Group confirms acquisition by US investors — TechCrunch, 2025-10-10
  15. Hikvision USA, Inc. v. FCC, No. 23-1032 — US Court of Appeals for the D.C. Circuit, 2024-04-02
  16. Spyware maker NSO Group blocked from WhatsApp — TechCrunch, 2025-10-18
Cite this research: PhantomGuide Research Team, “Sanctioned Surveillance Firms and the Western Companies Still Supplying Them”, PhantomGuide, 2026-10-01, https://phantomguide.com/research/sanctioned-surveillance-firms/

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