In 2021, German media published their findings of an investigation claiming German engine technology was being used in Chinese military warships.[1] According to the report, two companies were identified as providing marine diesel engines. These companies were MTU and the French branch of MAN, a Volkswagen subsidiary. Both companies have reported they are compliant with the dual-use export control regulations and have been involved with China’s military in the past. The German media outlet reported that MTU was at least as recently as 2020 supplying engines for Luyang III missile destroyers via a production plant inside China.[2] MTU has also reportedly supplied engines to the Song class of submarines but have stopped. While they claim to have not been contracted by any Chinese defense entity, their 2010 joint venture with the company Tognum had “noted deliveries of ‘marine engines for the Chinese navy and coast guard.”[3] The MAN subsidiary, SEMT Pielstick, published on their website its shipment of PA6 engines for frigate generation in China in 2002. They noted that these engines are considered dual-use and did not require an export license. These instances highlight the need for effective due diligence beyond dual-use controls to prevent risks to the company beyond legality, such as reputational risks. These also pose potential national security risks as companies aid, willingly or unknowingly, to the advancement of China’s rapidly growing naval fleet. Footnotes [1] https://www.theweek.in/news/world/2021/11/07/german-engines-powering-china-warships-eu-arms-ban-torpedoed-by-dual-use-tech.html [2] https://www.dw.com/en/german-engine-technology-found-in-chinese-warships-report/a-59740301 [3] Ibid.