No, it is not. It is a UK property belonging to a UK located landlord. It will have no bearing.
The lease predates the newer regulations like the Entity List designation and the CHIPS Act provisions. It is typically therefore grandfathered in under previous rules.
The lease is for physical property located in the UK. The US rules are focused on export controls and domestic investments, so they do not directly apply to a foreign real estate transaction.
Huawei's role as landlord is circumstantial and passive. This is not an active business collaboration that raises data or technology sharing concerns.
A basic real estate lease is fairly routine business activity. It does not imply a deeper partnership or investment with Huawei.
NWBO is not providing Huawei any technology, equipment or other exports that could be regulated by US trade controls.
NWBO is not investing in Huawei or forming a joint venture arrangement that could raise financial oversight issues.
However, the NWBO team itself and their counsel are likely very much aware of those issues and it’s doubtful they have not previously considered all of the issues. I would not claim legal expertise, but I expect that the NWBO team has all the legal advice they need and ever needed to ensure they insulated themselves. In fact they went into great detail about the security on the grounds and other protections related to Huawei being their landlord in one of their annual meetings, as I recall.
I am glad I was so loud on those issues when all of this first came up.
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