We write to better understand Anzu Robotics’ relationships with People’s Republic of China (PRC) Unmanned Aerial Vehicle (UAV) manufacturer SZ DJI Technology Co., Ltd. (DJI), a company on the Commerce Department’s Entity Listi that holds approximately 80% of the global drone market share.
As described in detail below, security researchers have confirmed that Anzu’s Raptor T is essentially a DJI Mavic 3 painted green, with its remote control and application all running on DJI technology. DJI’s partnership with Anzu came to light shortly after a congressional committee unanimously voted out legislation that would add DJI (or any subsidiary or affiliate thereof) to the Federal Communications Commission’s (FCC’s) Covered List, resulting in new models of DJI drones being prohibited from operating on U.S. communications infrastructure.
Based in part on your own statements, it appears that DJI is using Anzu as a passthrough company in an attempt to avoid current and anticipated U.S. restrictions on DJI products.
Beyond state action and anticipated federal legislation, these restrictions would also include restraints that the Commerce Department, the Department of Defense (DOD) under Section 1260H of the National Defense Authorization Act for Fiscal Year 2021, and other Executive Branch departments and agencies have already placed on DJI products.
DJI maintains close ties to the PRC government, though DJI long sought to obscure this fact. On its official blog, DJI has alleged that it “did not receive any Chinese government investments.”
However, contrary to DJI’s false statements, an IPVM/Washington Post investigation revealed that “at least four PRC government entities have invested in DJI,” including:
China Chengtong Holdings Group, “a 100% subsidiary of SASAC, the State-Owned Assets Supervision and Administration Commission of the State Council, the PRC government entity which administers the country’s vast State-Owned Enterprise sector.” China Chengtong states that “military-civilian integration” is a core “goal” of the company.
Shanghai Venture Capital Guidance Fund, “which is administered under the Shanghai Municipal Government” and mixes “state assets with private funds to advance Beijing’s industrial development goals in emerging industries.”
Guangdong Hengjian Investment Holding, a state-run PRC fund that has invested in andwith sanctioned companies including SenseTime, which was added to the BidenAdministration’s sanctions list for human rights violations in Xinjiang.viii
SDIC Unity Capital, “a state-owned investment holding company approved by China’sState Council.”ixDJI has also expressed allegiance to Chinese Communist Party (CCP) General SecretaryXi Jinping’s authoritarian practices. For example, Chinese websites show China Chengtong’sdeputy party secretary visiting a DJI facility to “conduct special research” on its investment.xChina Chengtong’s website states that its goals are “to mainly serve the innovation anddevelopment of central enterprises … and increase capital support for major national strategiessuch as the Belt and Road project and military-civilian fusion.”xi An article reporting on thedeputy party secretary’s visit to the DJI facility confirmed that “DJI adheres to the guidance ofXi Jinping Thought.”xii Xi Jinping Thought includes “ensuring party leadership over all work”and “upholding absolute [Chinese Communist] Party leadership over the people’s forces.”xiiiThe U.S. government has repeatedly found that DJI poses national security andcybersecurity risks. For example, DOD found that “systems produced by [DJI] pose potentialthreats to national security”xviiixiv and designated DJI as a Chinese Military Company;xv the TreasuryDepartment prohibited U.S. investors from investing in DJI on human rights grounds afterdetermining that “DJI has provided drones to the Xinjiang Public Security Bureau, which areused to surveil Uyghurs in Xinjiang;”xvi and the Commerce Department added DJI to its EntityList (banning U.S.-based companies from exporting technology to the company).xvii DODsuspended procurement of off-the-shelf DJI drones and the Department of the Interior hasgrounded all DJI and PRC-manufactured drones that it purchased.Notwithstanding such designations, your company appears to presently sell DJI’s Mavic3 drone painted in green as the “Anzu Raptor T.” Based on a review of the availabledocumentation, Anzu did not disclose its relationship with DJI in its filings with the FCC, evenwhile the Anzu drone was found to include DJI parts.xixInstead, your company only revealed its partnership with DJI after security researcherspublicized the fact that Anzu’s Raptor T was in fact a repainted DJI Mavic 3.xx After the security community confirmed these facts, both Anzu and DJI divulged their partnership, with aDJI spokesperson acknowledging that “DJI has a business partnership with Anzu Robotics [that]was established with the goal of enhancing the accessibility of capable and cost-effective dronein the market.
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