Total Loans Identified
$27.6M+
Across 12 US entities
Already Recovered (FCA)
$28.9M+
BWI $21.6M + Greenland $7.3M
Potential New Damages (3×)
$20M+
Unresolved targets, treble
DOD 1260H Listings
2
Inspur + BGI Group
BIS Entity List Hits
2
Inspur + BGI Group
Corporate Families
7
Across 11 US states
FCA Settlements
2
E.D. Wisconsin (2025)
High-Priority Unresolved
3
Inspur, BGI, Sinomax
⚖️ PPP LEGAL FRAMEWORK — Ineligibility Grounds for Chinese-Owned Companies
▶ Expand
Round 1 (Mar 2020 – Jan 2021)
- 13 C.F.R. § 120.110(j): Businesses owned by government entities are ineligible — includes foreign SOEs and SASAC-controlled companies
- SBA Size Standards: Affiliation rules require counting all affiliated entity employees globally; most Chinese SOE US subsidiaries exceed applicable NAICS size standards
- Affiliation Rules: Ownership control and economic interdependence with foreign parent triggers affiliation for size calculation
Round 2 (Jan 2021 – May 2021)
- All Round 1 exclusions remain in force
- Consolidated Appropriations Act 2021, § 311: Ineligible if entity or any 20%+ owner is "created or organized in a country that is a covered nation" — China is a covered nation
- Applies to PRC-organized entities even if privately held (not just government-owned)
- Strongest theory: Round 2 loans to ANY Chinese-owned US company (20%+ PRC entity/national) are facially ineligible
False Claims Act Standard
- 31 U.S.C. § 3729: Liability for knowingly submitting false claims to federal government
- Damages: Treble damages + civil penalties per false claim
- Qui Tam: Private relators receive 15–30% of recovery; government intervention vs. non-intervention affects relator share
- Key Precedent: E.D. Wisconsin settlements (2025) confirm viability of government-ownership theory
▶
BWI Group (3 US Entities)
Kettering OH · Brighton MI · Greenfield IN | Automotive brake & suspension systems | Beijing SASAC → BWI Group
$14,079,117
✓ FCA SETTLED
$21.6M Recovery
Govt Entity
Round 1
STATUS: RESOLVED — FCA SETTLED AUGUST 2025
E.D. Wisconsin
NAICS: Manufacturing
Business Summary
Automotive brake and suspension system manufacturer. US subsidiaries supply to GM, Ford, and Chrysler. 700+ US employees, 10,000+ globally across affiliates at time of loan application.
Government Ownership
Beijing SASAC (State-Owned Assets Supervision and Administration Commission of Beijing) — a direct Chinese municipal government body — is the ultimate owner of BWI Group. This represents the strongest possible government entity exclusion case under PPP rules.
DOD 1260H — Not Listed
BIS Entity List — Not Listed
OFAC SDN — Not Listed
USTR 301 — Not Listed
Implementation Status
Ownership Structure — 3 Levels
🏛 LEVEL 1 — ULTIMATE OWNER (Chinese Government)
State-Owned Assets Supervision and Administration Commission of Beijing (Beijing SASAC) — Chinese municipal government body; directly controls state assets; strongest possible government entity exclusion basis
↓ Controls (majority ownership)
🏢 LEVEL 2 — CHINESE PARENT
Beijing West Industries Group Co., Ltd. (BWI Group) — Automotive components multinational headquartered in Beijing; majority-owned by Beijing SASAC; 10,000+ global employees
↓ 100% Subsidiary
🇺🇸 LEVEL 3 — US PPP BORROWERS
BWI North America Inc. (Kettering, OH) — $9,208,112
BWI Chassis Dynamics (NA), Inc. (Brighton, MI) — $3,393,480
BWI Indiana Inc. (Greenfield, IN) — $1,477,525
BWI Chassis Dynamics (NA), Inc. (Brighton, MI) — $3,393,480
BWI Indiana Inc. (Greenfield, IN) — $1,477,525
| Entity | State | Loan Amount | Date | Round |
|---|---|---|---|---|
| BWI North America Inc. | OH | $9,208,112 | 04/28/2020 | Round 1 |
| BWI Chassis Dynamics (NA), Inc. | MI | $3,393,480 | 04/27/2020 | Round 1 |
| BWI Indiana Inc. | IN | $1,477,525 | 04/28/2020 | Round 1 |
| TOTAL | $14,079,117 | |||
- PRIMARYGovernment Entity Exclusion: PPP rules explicitly excluded businesses owned by government entities. Beijing SASAC is a government entity — this is the direct and strongest basis for ineligibility.
- SECONDARYSize Standard Violation: Global affiliate employee count (10,000+) far exceeded SBA standards for their NAICS manufacturing code. Affiliation rules required counting all global affiliates under common government ownership.
- TERTIARYFalse Certification: Applicants certified eligibility knowing they were ineligible under government entity exclusion and/or size standard rules.
- RECOVERYSettlement: $21,660,983 (August 2025, E.D. Wisconsin). Qui Tam relator GNGH2 Inc. received $2,166,098.30 (10% relator share).
Settlement Amount
$21,660,983
Settlement Date
August 2025
District
Eastern District of Wisconsin
DOJ Trial Attorney
Lindsey Roberts (Civil Division)
AUSA
Michael Carter
Qui Tam Relator
GNGH2 Inc. → received $2,166,098.30
DOJ Press Release
Attorney Notes
▶
Greenland USA (3 US Entities)
Los Angeles, CA | Real estate development (Metropolis LA) | Shanghai Government → Greenland Holdings
$5,922,161
✓ FCA SETTLED
$7.3M Recovery
Round 1 + 2
Dual Basis R2
STATUS: RESOLVED — FCA SETTLED DECEMBER 2025
E.D. Wisconsin
Round 1 + Round 2 Loans
Business Summary
Real estate development — Metropolis Los Angeles luxury condominium/hotel project in Downtown LA. At peak, Greenland Holdings was the world's largest real estate developer by floor space ($247B revenue in 2016, 100,000+ global employees). US entities are part of the Metropolis LA development.
Government Ownership
Shanghai Municipal Government (Shanghai SASAC) owns 46.37% of Greenland Holdings directly. Additional state entities bring effective government control above 50%. Founded 1992 as a Shanghai state-owned enterprise. Listed on SSE (600606).
DOD 1260H — Not Listed
BIS Entity List — Not Listed
OFAC SDN — Not Listed
USTR 301 — Not Listed
Implementation Status
Ownership Structure — 3 Levels
🏛 LEVEL 1 — ULTIMATE OWNER (Shanghai Government)
Shanghai Municipal Government (Shanghai SASAC) — 46.37% direct stake confirmed by company's own shareholder disclosures; additional state entities bring effective control above 50%; founded 1992 as Shanghai state-owned enterprise
↓ 46.37%+ ownership (effective majority control)
🏢 LEVEL 2 — CHINESE PARENT (SSE: 600606)
Greenland Holding Group Company Limited (绿地控股集团股份有限公司) — World's largest real estate developer by floor space at peak; $247B revenue (2016); 100,000+ global employees; PRC-organized entity
↓ 100% Subsidiary
🇺🇸 LEVEL 3 — US PPP BORROWERS (All Los Angeles, CA)
Greenland LA Metropolis Hotel Development LLC — $2,000,000 (R2) + $1,786,247 (R1)
Greenland US Management LLC — $1,067,957 (R1)
Greenland US Commercial Holding Inc. — $1,067,957 (R2)
Greenland US Management LLC — $1,067,957 (R1)
Greenland US Commercial Holding Inc. — $1,067,957 (R2)
| Entity | State | Loan Amount | Date | Round |
|---|---|---|---|---|
| Greenland LA Metropolis Hotel Development LLC | CA | $2,000,000 | 02/12/2021 | Round 2 |
| Greenland LA Metropolis Hotel Development LLC | CA | $1,786,247 | 06/26/2020 | Round 1 |
| Greenland US Management LLC | CA | $1,067,957 | 04/27/2020 | Round 1 |
| Greenland US Commercial Holding Inc. | CA | $1,067,957 | 02/08/2021 | Round 2 |
| TOTAL | $5,922,161 | |||
- R1 — PRIMARYSize Standard Violation: Greenland Group has 100,000+ global employees, vastly exceeding SBA size standards. Affiliation rules required counting global affiliates under common ownership/control.
- R2 — DUAL BASIS(a) Size standard violation (same as above) AND (b) 20%+ PRC entity ownership — Shanghai government/SASAC are PRC entities; Greenland Holdings itself is organized in PRC. Round 2 explicitly barred loans to companies 20%+ owned by PRC-organized entities.
- SECONDARYFalse Certification: False certifications on BOTH rounds — applicants knew or should have known they were ineligible based on global size and PRC ownership structure.
- RECOVERYSettlement: $7,312,283.36 (December 2025). Qui Tam relators: GNGH2 Inc. received $697,757.80 + Aidan Forsyth received $33,470.53.
Settlement Amount
$7,312,283.36
Settlement Date
December 2025
District
Eastern District of Wisconsin
DOJ Trial Attorney
Lindsey Roberts (Civil Division)
AUSA
Michael Carter (same team as BWI)
Qui Tam Relators
GNGH2 Inc. ($697,757.80) + Aidan Forsyth ($33,470.53)
DOJ Press Release
Attorney Notes
▶
Sinomax East, Inc.
La Vergne, TN | Polyurethane foam manufacturing (mattresses, Walmart/Amazon) | Sinomax Group (Foshan, China)
$2,275,332
🎯 NEW TARGET
Size Standard
Round 1
EQ: Medium
STATUS: UNRESOLVED NEW TARGET
NAICS: 326140
Evidence Quality: MEDIUM
Business Summary
Polyurethane memory foam manufacturing for mattresses, pillows, and toppers. Sells to major retailers including Walmart, Amazon, and Costco. US operation under the brand "Sinomax USA." One of the world's largest polyurethane foam manufacturers globally.
Ownership
Privately held — Sinomax Group (新马工业有限公司), headquartered in Foshan, Guangdong, China. Founded by PRC nationals. Note: NOT a government-owned entity — this is primarily a size standard case.
Estimated Treble Damages
~$6.8M
3× $2,275,332 loan amount
DOD 1260H — Not Listed
BIS Entity List — Not Listed
OFAC SDN — Not Listed
USTR 301 — Not Listed
Implementation Status
Ownership Structure — 3 Levels
👤 LEVEL 1 — ULTIMATE OWNER (Private PRC Nationals)
Sinomax Group (新马工业有限公司) — Privately held; headquartered Foshan, Guangdong, China; founded by PRC nationals; one of world's largest polyurethane foam manufacturers; 3,000+ global employees (China, US, UK)
↓ 100% Ownership
🏢 LEVEL 2 — INTERMEDIATE HOLDING
Sinomax Group International Holdings — Holding company for US, UK, and global operations
↓ 100% Subsidiary
🇺🇸 LEVEL 3 — US PPP BORROWER
Sinomax East, Inc. — La Vergne, Tennessee (Rutherford County); manufacturing facility; also operates as "Sinomax USA"; 220 reported US employees
| Entity | State | Loan Amount | Date | Round |
|---|---|---|---|---|
| Sinomax East, Inc. | TN | $2,275,332 | 04/11/2020 | Round 1 |
- PRIMARYSize Standard Violation: SBA size standard for NAICS 326140 is 750 employees. Sinomax Group employs 3,000+ globally. Affiliation rules require counting all affiliated entities under common ownership/control. Global headcount significantly exceeded size standard at time of application.
- SECONDARYPRC National Majority Ownership: Sinomax Group is majority-owned by PRC nationals. While Round 1 did not explicitly bar PRC national ownership (only government entity exclusion), the size standard argument alone is compelling.
- NOTEThis is primarily a SIZE STANDARD case, not a government ownership case. Weaker than BWI/Greenland but still viable FCA target given $2.275M loan amount and ~$6.8M treble damages exposure.
⚠️ Investigation Required: Verify global employee count and corporate structure via TN Secretary of State + foreign corporate filings. Evidence quality assessed as MEDIUM — confirm 3,000+ global employees through independent sources.
Attorney Notes
Key Sources: sinomax-usa.com (confirms US operations subsidiary of Chinese parent); TN SOS business registration for Sinomax East Inc.; SBA PPP public data
▶
Inspur USA Inc. ⭐ HIGHEST PRIORITY
Bellevue, WA | IT servers, cloud computing, AI platforms | Shandong SASAC → Inspur Group (SSE 600756)
$1,298,510
🎯 HIGH PRIORITY TARGET
🛡️ DOD 1260H
🚫 BIS Listed
Round 2
EQ: High
STATUS: UNRESOLVED — HIGHEST PRIORITY
Round 2 (March 2021)
Evidence Quality: HIGH
🚨 CRITICAL FACTS:
- DOD 1260H listing as "Chinese Military Company" — predates the loan (listed June 2020; loan taken March 2021)
- Round 2 loan = DUAL ineligibility: government entity exclusion + PRC entity ownership bar
- BIS Entity List addition confirms ongoing national security concern
- Shandong SASAC ownership is documented and verifiable via public filings
Business Summary
IT servers, cloud computing infrastructure, big data, and AI platforms. World's 3rd largest server manufacturer. Major supplier to Alibaba, Tencent, and Baidu in China; expanding US enterprise sales. 50,000+ global employees. US subsidiary handles sales and marketing for cloud/server products.
Estimated Treble Damages
~$3.9M
3× $1,298,510 loan amount
DOD 1260H ✅ LISTED — Chinese Military Company (June 2020)
BIS Entity List ✅ LISTED — March 2023; Aivres Systems also listed March 2025
OFAC SDN — Not Listed
USTR 301 — Not Listed
Implementation Status
Ownership Structure — 3 Levels
🏛 LEVEL 1 — ULTIMATE OWNER (Shandong Provincial Government)
Shandong State-Owned Assets Supervision and Administration Commission (Shandong SASAC) — Provincial-level Chinese government body controlling state assets in Shandong Province; controls majority of Inspur Group. DOD IDENTIFIED AS GOVERNMENT ENTITY.
↓ Majority government ownership
🏢 LEVEL 2 — CHINESE PARENT (SSE: 600756 / SZSE: 000977 / SEHK: 596)
Inspur Group Co., Ltd. (浪潮集团有限公司) — Jinan, Shandong; Revenue 63.2B yuan (2015); 50,000+ global employees; World's 3rd largest server manufacturer; DOD 1260H "Chinese Military Company" since June 2020; BIS Entity Listed March 2023
↓ 100% Subsidiary
🇺🇸 LEVEL 3 — US PPP BORROWER
Inspur USA Inc. — 10900 NE 8th St, Bellevue, WA 98004; US sales and marketing arm for Inspur cloud/server products; 63 reported US employees; Round 2 loan taken March 12, 2021 — AFTER DOD 1260H listing
| Entity | State | Loan Amount | Date | Round |
|---|---|---|---|---|
| Inspur USA Inc. | WA | $1,298,510 | 03/12/2021 | Round 2 |
⚠️ Round 2 loan taken March 2021 — AFTER January 2021 rule change adding PRC entity ownership bar AND after DOD 1260H listing (June 2020)
- PRIMARYGovernment Entity Exclusion: Shandong SASAC is a Chinese provincial government body. Inspur Group is majority government-owned. PPP explicitly excluded businesses owned by government entities. DOD 1260H listing corroborates government/military nexus.
- R2 — DUALRound 2 PRC Entity Ownership Bar: Inspur USA is directly owned by Inspur Group, a PRC-organized entity. This satisfies the 20%+ PRC entity ownership bar added by the Consolidated Appropriations Act 2021, § 311, effective January 2021 — two months before the loan was taken.
- TERTIARYSize Standard Violation: 50,000+ global employees across Inspur's affiliates vastly exceeds any applicable SBA size standard. Independent basis for ineligibility.
- TIMINGTimeline is devastating: DOD 1260H listing June 2020 → Round 2 PRC bar effective January 2021 → Inspur USA takes loan March 12, 2021. Every ineligibility ground was clearly established BEFORE the application.
Key Sources
DOD 1260H official list (Jan 2025 PDF); Shandong SASAC ownership documentation; BIS Entity List Federal Register notice (March 2023); SBA PPP public dataset; Wikipedia/Inspur Group
Attorney Notes
▶
BGI Group (2 US Entities)
Kennesaw GA · Cambridge MA | Genomics, genetic sequencing, COVID testing | BGI Group (Shenzhen) → BGI Genomics (SZSE: 300676)
$1,856,680
⚠️ POTENTIAL TARGET
🛡️ DOD 1260H
🚫 BIS Listed
Round 1
EQ: Medium-High
STATUS: POTENTIAL TARGET
Round 1 (April 2020)
Evidence Quality: MEDIUM-HIGH
Business Summary
Genomics, genetic sequencing, COVID-19 testing (supplied COVID tests globally), prenatal genetic testing (NIFTY test), bioinformatics, and agricultural genomics. BGI Americas Corporation (Cambridge, MA — formerly Complete Genomics) handles research/lab operations. BGI Group Inc. handles US commercial operations. 10,000+ global employees in 100+ countries.
Ownership & Government Links
Wang Jian (PRC national) is co-founder and Chairman. BGI is "supported by several China Government Guidance Funds and Chinese state-owned enterprises." BGI Research operates China National GeneBank under Chinese government contract — blurs line between private and state entity. BGI Genomics listed on SZSE (300676).
Estimated Treble Damages
~$5.6M combined
3× $1,856,680 combined loan amounts
DOD 1260H ✅ LISTED — BGI Group "Chinese Military Company"
BIS Entity List ✅ LISTED — BGI Genomics, MGI Tech, Forensic Genomics International
OFAC SDN — Not Listed
USTR 301 — Not Listed
Implementation Status
Ownership Structure — 3 Levels
👤 LEVEL 1 — ULTIMATE OWNER (PRC National + Govt-Backed)
BGI Group (深圳华大基因科技有限公司) — Shenzhen; Wang Jian (PRC national) co-founder & Chairman; "supported by China Government Guidance Funds and Chinese SOEs"; operates China National GeneBank under government contract; DOD 1260H "Chinese Military Company"
↓ Parent company / controlling ownership
🏢 LEVEL 2 — CHINESE PARENT (SZSE: 300676)
BGI Genomics Co., Ltd. — Listed on Shenzhen Stock Exchange (300676); parent of BGI Americas; 10,000+ global employees in 100+ countries; BIS Entity Listed alongside MGI Tech and FGI
↓ 100% Subsidiary
🇺🇸 LEVEL 3 — US PPP BORROWERS
BGI Group Inc. (Kennesaw, GA) — US commercial operations; 134 reported employees; $1,183,600
BGI Americas Corporation (Cambridge, MA) — Research/lab; formerly Complete Genomics; 31 reported employees; $673,080
BGI Americas Corporation (Cambridge, MA) — Research/lab; formerly Complete Genomics; 31 reported employees; $673,080
| Entity | State | Loan Amount | Date | Round |
|---|---|---|---|---|
| BGI Group Inc. | GA | $1,183,600 | 04/13/2020 | Round 1 |
| BGI Americas Corporation | MA | $673,080 | 04/13/2020 | Round 1 |
| TOTAL | $1,856,680 | |||
- PRIMARYPRC National Majority Ownership: Wang Jian (PRC national) is controlling owner/chairman. BGI Group is majority-owned by PRC nationals. While Round 1 did not explicitly bar PRC national ownership, combined with government investment vehicles this supports ineligibility.
- SECONDARYGovernment-Linked Ownership: BGI is backed by China Government Guidance Funds (government-directed investment vehicles) and Chinese SOEs as investors. BGI Research operates the China National GeneBank under government contract — blurs the line between private and state entity. May support government entity exclusion theory.
- SECONDARYSize Standard Violation: 10,000+ global employees in 100+ countries vastly exceeds SBA size standards. Independent and strong standalone argument.
- NOTEBoth loans are Round 1 (April 2020). Government entity exclusion argument is weaker than pure SOE cases. DOD 1260H and BIS listings are strong national security evidence but were made after the loans. The size standard argument stands alone and independently.
Key Sources
Wikipedia/BGI Group; DOD 1260H list; BIS Entity List Federal Register; BGI Genomics Shenzhen Stock Exchange disclosures (300676)
Attorney Notes
▶
China Oceanwide Holdings (4 US Entities)
San Francisco CA · Los Angeles CA · Honolulu HI · Houma LA | Real estate, offshore staffing | Lu Zhiqiang (PRC national, ~90%)
$1,812,336
⚠️ POTENTIAL TARGET
⚠️ In Bankruptcy
Round 1 + 2
EQ: Medium
STATUS: POTENTIAL TARGET
Company in Bankruptcy (2022)
Evidence Quality: MEDIUM
⚠️ Bankruptcy Complication: China Oceanwide filed for bankruptcy/receivership in US courts in 2022. Oceanwide Center SF and Oceanwide Plaza LA remain stalled/in receivership. Recovery may compete with other creditors. Projects include Oceanwide Center SF (planned 605-foot tower) and Oceanwide Plaza LA (planned 4-tower luxury complex) — both unfinished.
Business Summary
Real estate development (SF and LA mega-projects), hotel/resort, and offshore oil services staffing. China Oceanwide was formerly a Shenzhen Stock Exchange-listed real estate and financial conglomerate. US assets included high-profile but stalled development projects.
Ownership
Lu Zhiqiang (卢志强) — PRC national billionaire with approximately 90%+ controlling ownership stake in China Oceanwide Holdings Group (SZSE: 000046).
DOD 1260H — Not Listed
BIS Entity List — Not Listed
OFAC SDN — Not Listed
USTR 301 — Not Listed
Implementation Status
Ownership Structure — 3 Levels
👤 LEVEL 1 — ULTIMATE OWNER (PRC National Billionaire)
Lu Zhiqiang (卢志强) — PRC national; former Forbes China billionaire; controlling shareholder with approximately 90%+ ownership stake in China Oceanwide Holdings Group
↓ ~90%+ controlling ownership
🏢 LEVEL 2 — CHINESE PARENT (SZSE: 000046) — IN BANKRUPTCY
China Oceanwide Holdings Group Co., Ltd. (泛海控股集团有限公司) — Real estate and financial conglomerate; formerly listed on SZSE; US assets included planned luxury towers in SF and LA; filed bankruptcy December 2022
↓ 100% Subsidiary
🇺🇸 LEVEL 3 — US PPP BORROWERS (4 Entities)
Oceanwide Center LLC (San Francisco, CA) — $511,673 R1
Oceanwide Plaza LLC (Los Angeles, CA) — $473,559 R1
Oceanwide Resort Hi LLC (Honolulu, HI) — $265,670 R1
Oceanwide Staffing, Inc. (Houma, LA) — $323,600 R1 + $237,834 R2
Oceanwide Plaza LLC (Los Angeles, CA) — $473,559 R1
Oceanwide Resort Hi LLC (Honolulu, HI) — $265,670 R1
Oceanwide Staffing, Inc. (Houma, LA) — $323,600 R1 + $237,834 R2
| Entity | State | Loan Amount | Date | Round |
|---|---|---|---|---|
| Oceanwide Center LLC | CA | $511,673 | 04/28/2020 | Round 1 |
| Oceanwide Plaza LLC | CA | $473,559 | 04/27/2020 | Round 1 |
| Oceanwide Resort Hi LLC | HI | $265,670 | 04/29/2020 | Round 1 |
| Oceanwide Staffing, Inc. | LA | $323,600 | 08/06/2020 | Round 1 |
| Oceanwide Staffing Inc. | LA | $237,834 | 04/08/2021 | Round 2 |
| TOTAL | $1,812,336 | |||
- R2 — PRIMARYPRC Entity Ownership Bar (Round 2): Oceanwide US entities are 100% owned through China Oceanwide Holdings (a PRC-organized entity). Round 2 explicitly barred loans to businesses 20%+ owned by PRC-organized entities. Oceanwide Staffing's Round 2 loan ($237,834) is directly and facially ineligible.
- R1 — PRIMARYPRC National Majority Ownership + Size Standard: Lu Zhiqiang as ~90% PRC national owner. While Round 1 didn't explicitly bar PRC national ownership, size standard argument applies — China Oceanwide had global operations with thousands of employees across all divisions.
- COMPLICATIONBankruptcy Risk: Company is in bankruptcy/receivership since 2022. FCA recovery may compete with other creditors. Below $2.5M threshold individually; combined $1.8M is viable but complex. Recommend assessing bankruptcy proceedings status before investing significant resources.
Attorney Notes
▶
HNA Group North America LLC
New York, NY | Investment holding (Hilton, Deutsche Bank stakes) | Hainan Province Government (70%) → HNA Group
$889,035
⚠️ POTENTIAL TARGET
⚠️ Parent Bankrupt
Round 1 + 2
Govt Takeover R2
EQ: Medium
STATUS: POTENTIAL TARGET
HNA Group Bankrupt Dec 2021
Evidence Quality: MEDIUM
⚠️ Bankruptcy Complication: HNA Group Co., Ltd. declared bankruptcy December 8, 2021. US operations largely wound down. However, the Round 2 loan (March 2021) was taken while Hainan provincial government had already assumed de facto control — creating both government ownership and PRC entity arguments.
Business Summary
US holding company managing HNA Group's North American investments including former stakes in Hilton Hotels & Resorts, Deutsche Bank, and NH Hotels. At peak, HNA Group was Fortune Global 500 #170 (2017, revenue $53B) spanning aviation, hotels, real estate, and financial services. 30 reported US employees at HQ.
Government Ownership
Hainan Traffic Administration Holding owns 70% of HNA Group. Hainan provincial government effectively took over HNA Group management during 2020-2021 financial crisis before formal bankruptcy. By the time of the Round 2 loan (March 2021), Hainan province was in de facto control.
DOD 1260H — Not Listed
BIS Entity List — Not Listed
OFAC SDN — Not Listed
USTR 301 — Not Listed
Implementation Status
Ownership Structure — 3 Levels
🏛 LEVEL 1 — ULTIMATE OWNER (Hainan Provincial Government)
Hainan Province Government (Hainan Traffic Administration Holding) — Owns 70% of HNA Group; effectively state-controlled by Hainan provincial government; took over HNA Group management during 2020-2021 financial crisis prior to formal bankruptcy
↓ 70% government ownership (de facto control by March 2021)
🏢 LEVEL 2 — CHINESE PARENT — BANKRUPT Dec 2021
HNA Group Co., Ltd. (海航集团有限公司) — Formerly Fortune Global 500 #170 (revenue $53B, 2017); aviation, hotels (Hilton stake), real estate, financial services; declared bankruptcy December 8, 2021; Hainan Airlines (SOE) was core asset; 100,000+ global employees
↓ 100% Subsidiary
🇺🇸 LEVEL 3 — US PPP BORROWER
HNA Group North America LLC — 153 E 53rd St, New York, NY 10022; US holding company for HNA Group's North American investments; 30 reported US employees; Round 1 + Round 2 loans taken
| Entity | State | Loan Amount | Date | Round |
|---|---|---|---|---|
| HNA Group North America LLC | NY | $436,320 | 05/01/2020 | Round 1 |
| HNA Group North America LLC | NY | $452,715 | 03/24/2021 | Round 2 |
| TOTAL | $889,035 | |||
- R2 — PRIMARYGovernment Entity Exclusion (Round 2): By March 2021, Hainan provincial government had effectively assumed control of HNA Group management. Hainan Traffic Administration Holding owned 70%. This is de facto government ownership, making HNA a government entity at the time of the Round 2 loan.
- R2 — DUALPRC Entity Ownership Bar (Round 2): 100% owned through HNA Group (PRC-organized entity), directly satisfying the 20%+ PRC entity bar under Consolidated Appropriations Act 2021, § 311.
- R1 — SIZESize Standard Violation (Round 1): HNA Group had 100,000+ employees globally across all divisions — vastly exceeds any applicable SBA size standard for affiliation analysis.
- KEY ISSUEDocumentary evidence needed on exact ownership timeline — need to establish precisely when Hainan provincial government assumed effective control relative to the Round 2 loan date (March 24, 2021). Government takeover/ownership timing is the pivotal factual question.
Attorney Notes