January 15, 2025 | Monograph
Biotech Battlefield
Weaponizing Innovation in the Age of Genomics
January 15, 2025 | Monograph
Biotech Battlefield
Weaponizing Innovation in the Age of Genomics
“Only by grasping the core technologies in our own hands will we be able to truly grasp the initiative in competition and development, and fundamentally guarantee our country’s economic security, defense security, and security in other [domains].”
Chinese Communist Party Chairman Xi Jinping, speaking before China’s Academy of Sciences in 20141
“The vast ocean of data, just like oil resources during industrialization, contains immense productive power and opportunities. Whoever controls big data technologies will control the resources for development and have the upper hand.”
Xi Jinping, in a 2013 address to the Chinese Academy of Sciences2
“Today, modern biotechnology that focuses on the microcosmos of the life structure can directly explore the main entity of war — human beings themselves — thus taking precise control of the battle effectiveness of enemies … We [China] can use many modern biotechnologies directly as a means of defense and attack, and with further development, they probably will become new weapons systems.”
Col. Guo Ji-wei, The People’s Liberation Army, 20053
“Under the leadership and strong support of the party and the government, BGI has a great foresight and leadership in the field of life sciences. We will continue to strengthen the leadership of Party building and achieve rapid development.”
BGI Chairman and Co-Founder Wang Jian, 20174
Introduction
In a sign of his unwavering commitment to self-reliance (自力更生), Chinese Communist Party (CCP) Chairman Xi Jinping has declared technological innovation to be the “main battlefield of the international strategic game.”5 Central to Xi’s vision is biotechnology, which he has identified as a critical sector in China’s bid to become a global science superpower.6
Xi’s broader ambitions are anchored in China’s military-civil fusion (军民 融合) strategy, which aims to break down barriers between military and civilian institutions to mobilize the latter in service of the former. Specifically, military-civil fusion facilitates the direct transfer of data and cutting-edge technologies to China’s People’s Liberation Army (PLA), ensuring that China’s military capabilities keep pace with rapid civilian technological progress. Biotechnology, with its vast potential to revolutionize fields such as genomics, synthetic biology, and bioengineering, is integral to military-civil fusion.
China’s military-industrial complex has long recognized the strategic importance of biotechnology, engaging in extensive collaborations with Chinese biotechnology behemoths like BGI Group (華大集團, or BGI) and its former subsidiary, MGI Tech (深圳华大智造科技股份有限公司). These and other partnerships have yielded research with potential military applications, including efforts to enhance Chinese soldiers’ physical and cognitive abilities. The PLA’s involvement in biotechnology research extends to its collaborations with select Chinese civilian universities, which, along with entities like BGI Group and MGI Tech, play a pivotal role in advancing China’s military-civil fusion strategy.
China’s civilian biotechnology advancements have also contributed to widespread human rights abuses, particularly in Xinjiang Province, where Chinese authorities exploit genetic data to surveil and repress ethnic minorities. These actions highlight how biotechnology, beyond its military applications, is reinforcing the authoritarian regime’s grip on society.
This report begins by exploring the growing importance of biotechnology within China’s national development strategy, with a particular focus on Xi Jinping’s prioritization of the field as pivotal to China’s military modernization. First, it examines the PLA’s increasing interest in biotechnology and its implications for China’s military capabilities. The report then delves into the ties between BGI, MGI Tech, and China’s military and state institutions, highlighting the significant risks these relationships pose to U.S. national security and global technological leadership. Finally, the report presents a series of policy recommendations designed to counter these threats, including measures to limit BGI’s and MGI’s influence and prevent their access to sensitive U.S. data and technologies.
Illustration by Daniel Ackerman/FDD
China’s Strategic Technological Ascent — The Critical Role of Biotechnology
Xi Jinping’s “innovation-driven development strategy” underpins his goal of transforming China into a “world science and technology leader.”7 First articulated at the 18th National Congress of the Chinese Communist Party in 2012, Xi’s strategy hinges on fully integrating China’s scientific community into the CCP’s broader technological agenda, with the explicit aim of winning “the battle of key core technologies.”8 By bolstering Chinese firms’ research capabilities and fostering new scientific discoveries, Xi’s goals include preventing China from becoming a “vassal of other countries” and cementing China’s centrality in next-generation supply chains.9 Biotechnology is integral to these efforts.
For the past decade, Xi has consistently emphasized to Chinese scientists and engineers that biotechnology is essential to China’s national growth and security. Speaking before the Chinese Academy of Sciences and the Chinese Academy of Engineering in May 2018, Xi identified biotechnology as a “frontier field” in which China must excel.10 He highlighted the need to “achieve major breakthroughs” in several biotechnology-related fields, including synthetic biology, stem cell research, gene editing, brain science, and regenerative medicine.11
In February 2020, as COVID-19 spread globally, Xi expanded his biotechnology focus by ordering party officials to “incorporate biosecurity into the national security system.”12 In that same speech, Xi also directed cadre members to “pay more attention to basic research in heredity, genetics, virology, epidemiology, immunology, and other life sciences.”
These ever-expanding scientific directives typify Xi’s “comprehensive national security” (总体国家安全, or CNS) concept, which integrates all aspects of China’s development — including scientific innovation — into the broader framework of state security.13 While ensuring political security — particularly regime stability and CCP supremacy — remains the paramount priority, biosecurity now ranks alongside nuclear, cyber, space, and military security as one of the CCP’s critical strategic imperatives.14
Xi’s speeches have directly shaped Chinese policy planning. China’s 12th Five-Year Plan (2011-2015), crafted before Xi’s rise, referenced biotechnology but focused on expanding international exchanges and cooperation in that sector and building “databases of gene resources for pharmaceuticals.” By contrast, the 13th Five-Year Plan (2016-2020), under Xi’s leadership, set ambitious goals for China to develop globally competitive biotechnology companies and achieve advanced biotechnology “breakthroughs.”15 By some estimates, China’s central, local, and provincial governments collectively invested $100 billion over this period to fulfill Xi’s biotechnology research and development (R&D) directives.16
China’s 14th and current Five-Year Plan (2021-25) surpasses its predecessors by explicitly prioritizing life sciences and biotechnology as national research priorities. The plan aims for China to lead the global bioeconomy by 2035 and includes commitments to increase biotechnology-related R&D investments by more than 10 percent annually.17 The plan also prioritizes integrating biotechnology with information technology and expanding party-state control over healthcare, bio-agriculture, bioenergy, biomedicine, and biosecurity.
Evolution of Chinese Biotechnology and Bioengineering Policy
In 2024, Xi identified life sciences and biotechnology as two of China’s “new productive forces” — industries he views as crucial for revitalizing the economy and positioning China at the forefront of the next industrial revolution.19 The 2024 Government Work Report, which outlines China’s macroeconomic plans, prioritized the development of these “new productive forces” as the CCP’s top policy objective.20 These announcements all but guarantee robust party-state support for China’s biotechnology sector, likely mirroring the industrial policies that previously propelled China’s telecommunications and drone sectors to global dominance.
To support China’s biotechnology ambitions, Xi has constructed a comprehensive legal and regulatory framework that ensures the party-state’s total control over genetic and biological resource management. Central to this framework is China’s 2020 Biosecurity Law.21 This law broadly defines biosecurity as encompassing various sub-domains, including biosafety risk assessment; pandemic early warning detection; the prevention and control of human and animal infectious diseases; and bioterrorism and bioweapons threats. This expansive definition grants the state unparalleled oversight and direction over critical biotechnology-related sectors, enabling tight control and strategic alignment with national priorities.
In Article 53, the law declares the party-state’s absolute sovereignty over China’s human genetic materials, biological samples, and related resources. The law grants the party-state direct control over all activities involving China’s national genetic materials, whether research institutions, companies, or individual scientists engage in them. In Articles 86 and 87, the law also obliquely references separate, non-public provisions regarding secret and/or military-related biosecurity initiatives, suggesting a potential linkage between China’s broader biotechnology drive and China’s military.
The law also establishes a new whole-of-party entity responsible for overseeing its implementation — the National Biosecurity Work Coordination Mechanism — consisting of representatives from various government ministries responsible for health, science and technology, agriculture, and foreign relations, as well as China’s military.
Other Chinese laws, including the 2016 Cybersecurity Law, also grant extensive government access to all private sector information in China, mandating that Chinese companies provide data, “technical support, and assistance to state security agencies.”22 China’s 2017 National Intelligence Law likewise obliges “all” Chinese citizens and organizations to assist in state intelligence work, further enhancing the party-state’s control over private sector data.23 These and other laws extend to companies harboring genomic or other personal data of Chinese nationals and foreigners alike, thereby advancing the genomics-related activities of not only civilian party-state entities but also the PLA and China’s intelligence services.
Transforming China into a biotechnology behemoth requires more than gaining access to genomic and healthcare data; it demands analysis of these complex datasets to produce new discoveries. Accordingly, to “strengthen national defense in tandem with economic growth,” the party-state, as well as China’s military and intelligence services, has invested billions to enhance the country’s artificial intelligence, big data, and super-computing capabilities.24 Beyond providing Chinese biotechnology companies with an edge over foreign competitors, these initiatives raise serious ethical and privacy dilemmas given the PLA’s stated interest in theoretical and applied genomic research.
All told, the PLA’s focus on biotechnology dates back more than two decades. In 1999, PLA Colonels Qiao Liang and Wang Xianghui published Warfare Beyond Rules, which advocated “warfare beyond all boundaries and limitations,” including the use of “biochemical,” “ideological war,” and other means of conflict.25 Later, in a groundbreaking 2005 article titled, “Looking Ahead to Military Biotechnology,” then PLA Colonel Guo Jiwei argued China needed to harness military biotechnology as an instrument of military power, including using biotechnology “as a means of defense and attack.”26 Guo noted, “Biotechnological weapons can cause destruction that is both more powerful and more civilized than that caused by conventional killing methods like gunpowder or nuclear weapons.”27
Guo further explained, “newly developed biotechnologies lend themselves to military purposes; for example, DNA recombination, gene modification, gene cloning, exogenous gene expression synergy, gene targeting, stem cell technology, and tissue engineering.”28 With these nascent technologies in mind, Guo chillingly predicted that “direct-effect” biotechnology weapons could target adversaries “at the molecular level” to alter their “biological features.”29
Guo, who wrote his 2005 article while serving as a professor at the PLA’s Third Military Medical University,30 a major military R&D institute, went on to publish a 2010 book titled, “War for Biological Dominance” (制生权战争), which argued that harnessing biotechnology was crucial for “future warfare,” necessitating PLA dominance in that sector.31 These seminal writings inspired a generation of PLA scientists and researchers.
For instance, He Fuchu (贺福初), then president of the PLA’s Academy of Military Medical Sciences (中国人民解放军军事科学院军事医学研究院, or AMMS), asserted in 2015 that biotechnology would become the new “strategic commanding height” of national defense, spanning biomaterials to “brain control weapons.”32 He later became vice president of the PLA’s Academy of Military Sciences (民解放军军事科学院, or AMS), which oversees AMMS. Xi Jinping subsequently tasked AMS to become a “world-class military scientific research institute” focusing on defense-related research in biotechnology, artificial intelligence, and quantum computing.33
Alongside its push to prioritize biotechnology R&D, the PLA has implemented significant shifts in its warfighting doctrine. For instance, in 2017, Zhang Shibo (张仕波), a now retired general who previously served as president of the PLA’s National Defense University, identified biology as one of seven “new domains of warfare,” specifically highlighting biotechnology’s potential to play a decisive role in “offensive” warfighting.34
Also in 2017, the PLA’s National Defense University published an updated edition of its Science of Military Strategy (战略学) textbook, which debuted a section identifying biology as a new domain (新兴领域) of “military struggle.”35 The textbook noted how new kinds of biological warfare, including “specific ethnic genetic attacks” (特定种族基因攻击), could be used against entire racial and ethnic groups.36
The textbook also discusses the PLA’s growing interest in gene-editing technologies, like clustered regularly interspaced short palindromic repeats (or CRISPR), focusing on human performance enhancement to boost the combat effectiveness of Chinese military personnel. Since the textbook’s publication, gene editing and military bioengineering have become key research areas for the PLA’s medical institutions.37 In 2021, the U.S. Department of Commerce restricted exports of advanced technology to the PLA’s AMMS by adding AMMS to the department’s Entity List, citing the academy for developing biotechnology processes for the PLA, to include contributing to China’s “brain-control” weapons development.38
Relatedly, PLA researchers have published studies on “Human Performance Enhancement Technology,” identifying CRISPR as one of three primary biotechnologies that could enhance Chinese troop effectiveness.39 One PLA study specifically examined the cognitive enhancement drug Modafinil and emphasized the “great potential” of CRISPR as a “military deterrence technology.”40 The study further argued that China should “grasp the initiative” in developing these capabilities, which other PLA officials, such as National University of Defense Technology (NUDT) researcher Zeng Huafeng, have deemed tools of “biological deterrence” (生物威慑).41
Amid the PLA’s intensified focus on weaponizing biotechnology, U.S. national security officials have repeatedly raised alarms about China’s growing access to U.S. genomic data. In 2017, the FBI warned that China had “gained significant access to U.S. genomic data and biological samples through research partnerships, investments, mergers, and acquisitions.”42 The U.S. Department of Defense has also highlighted the threats posed by China’s aggressive collection of genomic data, noting that such investments in biotechnology could lead to “enhanced warfighter selection and performance and advanced human-machine teaming.”43
A 2020 U.S. National Academy of Sciences report echoed these concerns, highlighting that low-cost DNA sequencing by Chinese firms could facilitate the Chinese government’s extensive collection of U.S. genetic information, with potential risks for targeting specific U.S. population subsets. The report emphasized that “[e]ven if genetic associations with behavior are not well understood at present, they will become better established as more research is conducted and more data are collected and analyzed.”44
In 2021, the U.S. National Counterintelligence and Security Center further cautioned that China’s collection of healthcare and genomic data posed “serious risks, not only to the privacy of Americans but also to the economic and national security of the United States.”45
BGI: Beijing’s Backbone in Biotech and Big Brother Surveillance
BGI Group (formerly Beijing Genomics Institute) stands as the foremost embodiment of Beijing’s biotechnology ambitions. As one of the world’s largest genomics and DNA sequencing companies, BGI claims to provide its services “for the benefit of all mankind.”46 Yet BGI also serves as a critical military-civil fusion enabler for the CCP, integrating advanced biotechnology research and equipment with state surveillance and military applications.
BGI’s rapid ascent has been fueled by significant Chinese government support, which BGI has openly acknowledged and leveraged to attract investment. For example, in corporate filings, BGI has advertised its mission to help the CCP “seize the commanding heights of international biotechnology competition.”47 Such statements blur the lines between BGI’s ostensible private sector status and its de facto role as an essentially state-controlled entity.
Fueled by the Party’s Purse
BGI has staunchly denied that it is owned by the Chinese government. But there is little question that the CCP’s financial backing played a major role in BGI’s rapid growth. This support has included direct capital infusions, tax incentives, and subsidies.48 These advantages allowed BGI to undercut U.S. and European competitors by offering products at prices well below market value — a strategy reminiscent of Chinese state-backed enterprises, like Huawei.
Strategic investments from the Chinese government were particularly pivotal in driving BGI’s early and ongoing success. For example, during its first decade, BGI secured a $1.5 billion loan from China Development Bank (2009-2010), which facilitated BGI’s purchase of 128 gene sequencing machines from U.S. firm Illumina.49 Afterward, Illumina accused BGI of patent infringement and illegally copying its proprietary sequencing chemistry. A series of lawsuits ensued in the United States, United Kingdom, Germany, Spain, and Finland.50
In 2013, the Export-Import Bank of China provided BGI with a $75 million loan to acquire California-based Complete Genomics Inc., then an emerging player in the life sciences sector.51 BGI’s purchase of Complete Genomics aligned with China’s 12th Five-Year Plan objectives, per Chinese government disclosures. China’s National Development and Reform Commission, a powerful CCP entity responsible for national economic strategy and advancing China’s dominance in the life sciences sector, cited the deal as fulfilling a Chinese government-directed “overseas acquisition” goal.52
These and other preferential loans from other Chinese government-backed banks demonstrate how Beijing has positioned BGI as not merely a business entity but a strategic asset. 53
Party Ties That Bind
Beyond financial support, the CCP wields significant control over BGI’s operations through various other channels, mirroring its grip on state-backed firms like battery maker Contemporary Amperex Technology Co., Limited (CATL) and social media giant ByteDance, TikTok’s parent company.54 This control manifests through strategically placed senior executives and a growing framework of laws, regulations, and party structures that appear to steer day-to-day decision-making — often in ways that remain opaque to international regulators, partners, and investors. These mechanisms raise serious questions about the company’s claims that it is neither “owned, funded, nor controlled by the Chinese Government.”55
BGI’s origin story traces directly back to China’s Academy of Sciences (CAS), a Chinese government-funded and directed institution responsible for spearheading defense-related research for China’s military.56 CAS is also a key player in China’s military-civil fusion ecosystem and operates dedicated military-civil fusion institutions, including a military-civil fusion big data research center and a military-civil fusion development center at its university.57 The U.S. Department of Commerce has placed numerous arms of CAS on its Entity List for their role in supporting China’s military modernization.58
According to CAS’s website, BGI originally operated as the Human Genome Research Centre at CAS’s Institute of Genetics.59 One of BGI’s co-founders even described the company’s relationship with CAS as consisting of “one name, two nameplates,” which serves to illustrate that while BGI is nominally private, it is and has always been heavily influenced by CAS and, by extension, China’s party-state and military.60
Moreover, BGI’s investment documents highlight its collaboration with China’s party-state, notably China’s National GeneBank, which the government established in 2011. Today, the GeneBank is one of the world’s largest repositories of genetic information, holding millions of genomic samples from both China and other countries. According to the GeneBank’s website, its mission is to “store, manage, and utilize genetic resources” to “serve China’s strategic needs,” which, by default, include those outlined in Xi Jinping’s comprehensive national security strategy.61 The GeneBank also states that while its samples are “owned by the [Chinese] government,” they are “managed by BGI,” further blurring the lines between the GeneBank, BGI, and the government.62
BGI’s presence in government-controlled innovation hubs like the Shenzhen International Biobay further solidifies its integration with the government.63 These hubs are integral to military-civil fusion, facilitating the direct transfer of data and cutting-edge technologies from nominally private companies to the PLA and Chinese intelligence services. To that end, the Shenzhen International Biobay’s administrative and governing units include an “Office of Party Affairs” to ensure CCP control and loyalty and an “Office of Technology Transfer,” with the PLA-affiliated CAS serving on Biobay’s governing board alongside BGI.64
Copy of the Biobay’s Corporate Leadership Structure, 2024. Source: https://www.szbl.ac.cn/en/about/organization/leadership/
The CCP’s de facto control over BGI also extends deeply into its personnel structure, ensuring alignment with government objectives. Under Xi’s party-first framework, which emphasizes deepening party control across all sectors, the most important official at BGI is not necessarily its CEO, Ye Yin, or even its chairman and co-founder, Wang Jian. Instead, it is BGI’s CCP commissar (or secretary), Dr. Du Yutao, a recipient of “Outstanding Party Worker” awards for her loyalty to the CCP and a delegate to the CCP’s national-level 19th Congress in 2017, where Xi’s new guiding ideology, known as “Xi Jinping Thought on Socialism with Chinese Characteristics for a New Era,” was written into the CCP’s constitution.65
In addition to her roles as CCP commissar and as a BGI corporate director, Du is also an active player in the CCP’s “United Front” system, a network of party and state organizations that carry out influence operations both domestically and abroad. She is a member of at least four organizations and platforms that report to various tiers of the United Front Work Department, each focused on recruiting Chinese and foreign-born scientists to support China’s biotechnology industry. These organizations are the Shenzhen Western Returned Scholars Association, the Returned Overseas Chinese Association of Yantian District, the Guangdong Youth Federation, and the Shenzhen Youth Federation.66 These positions endow Dr. Du with authority, both real and implied, to ensure BGI’s corporate decisions align with state priorities and data-sharing mandates.
Other senior BGI personnel have deep-rooted connections to security-affiliated institutions. For instance, BGI co-founder Yang Huanming served simultaneously during the company’s first decade as its legal representative while retaining an official position (and access to resources) at CAS.67 Similarly, Wang Jian served concurrently as chairman of BGI Group and deputy director of CAS’s Beijing Institute of Genomics from 2003 to 2007.68 Likewise, Mei Yonghong, BGI’s current executive vice president, previously served as deputy CCP secretary and mayor of Jining in Shandong province, a hub for military-civil fusion initiatives.69 Mei also held senior roles within China’s Ministry of Science and Technology, including director of policy, regulations, and system reform, placing him, along with Du, in a position to ensure implementation of key aspects of the military-civil fusion strategy.70
There is also an extensive network of embedded party cells within BGI. These groupings of CCP officials ensure BGI’s alignment with party directives and facilitate the party’s access to BGI’s data, research, and technology. According to Nanfang Daily, a CCP-owned newspaper, BGI had at least 25 party cells by 2017.71 Additionally, BGI’s subsidiaries maintain their own CCP cells, with one Shenzhen-based subsidiary alone hosting 10 CCP cells with more than 300 party members as of 2019.72 Other subsidiaries, such as BGI Marine and BGI College, also have embedded cells, reinforcing CCP control across BGI’s operations.73
Genomics in Service of the Security State
BGI is as much a data giant as it is a biotech firm. Co-founder Wang Jian aptly described BGI as a “big data company,” highlighting that its “greatest competitive power is its big data platform, computing, and analysis capabilities.”74 From the Chinese government’s perspective, the purpose of integrating genomics and big data extends beyond market dominance of a particular company to empowering Beijing’s police state. According to the U.S. government, BGI’s data capabilities have directly facilitated egregious human rights abuses, particularly in Xinjiang against Uyghurs and other ethnic minorities.75
While leveraging civilian businesses for military capabilities has long been CCP doctrine, Xi has dramatically expanded these initiatives, emphasizing the integration of private sector innovation into military advancements and dual-use technologies. For example, the PLA’s 2020 Science of Military Strategy report highlights biotechnology’s critical role in military-civil fusion, emphasizing that “local enterprises are often at the forefront of biotechnology development” and urging the military to “fully utilize” these private firms.76 The strategy also advocates for joint R&D projects between Chinese companies and the PLA as well as the construction and operation of biosafety laboratories essential to military research.
BGI reportedly hosts four Chinese government-funded “Key Laboratories” for genomic research.77 These types of labs, often jointly supervised by the PLA and co-located within Chinese universities or defense conglomerates, play a crucial role in advancing military-civil fusion.78 In BGI’s case, this likely includes facilitating cutting-edge research in biotechnology, biomedicine, and other life sciences.
There is ample evidence of BGI partnering with the PLA on military-relevant genomic studies. For example, in 2017, BGI researchers collaborated on sensitive research with the Third Military Medical University, the PLA’s Key Laboratory of High-Altitude Medicine, and the 18th Hospital of the PLA in Xinjiang.79 This research focused on investigating drug interactions with genes in Han Chinese to prevent brain damage at high altitudes — which happens to be a critical issue for Chinese troops enforcing Beijing’s control in Tibet.80 Notably, CAS has warned that brain damage and death caused by high altitude on the Tibetan plateau have severely hindered “national defense construction.”81 BGI’s joint brain damage research with the PLA also dovetails with the PLA’s other high-altitude mitigation efforts in Tibet, including recent upgrades to oxygen supply facilities to enhance PLA troop readiness.82
In 2019, BGI, the China National GeneBank, the PLA General Hospital, and the PLA Rocket Force Characteristic Medical Centre collaborated on a genetic study of hearing loss due to weapons training.83 This research closely aligns with studies spearheaded by the Military Medical Research Institute of the PLA’s Academy of Military Sciences. These include attempts to leverage biotechnology and bioengineering to produce “hearing enhancement devices” and “neurological drugs” to reverse “battlefield damage,” with the goal of ensuring the army’s ability to “fight and win battles.”84
Photo illustration of BGI Group logo. (Photo Illustration by Pavlo Gonchar/SOPA Images/LightRocket via Getty Images)
In 2020, BGI employees collaborated with the PLA’s Third Military Medical University on studies of brain injuries in monkeys subjected to extreme altitudes. CAS scientists praised the effort for its potential applications in future high-altitude military deployments.85 Beyond Tibet, the PLA’s Western Theater Command is actively working to increase its soldiers’ ability to operate in the cold and mountainous environment along the Sino-Indian border.86
Opening ceremony of the 15th International Congress on Genomics in Wuhan in 2020. (Photo via Annual Meeting of the International Conference on Genomics website, www.icg.bio)
For over a decade, BGI has also collaborated closely with China’s military to study fetal genomes, resulting in more than a dozen joint studies with PLA researchers aimed at refining BGI’s prenatal non-invasive fetal trisomy (NIFTY) tests.87 These tests, which detect genetic abnormalities such as Down Syndrome in early pregnancy, have been used by over 8 million women globally and are sold in at least 52 countries. While this work is focused on prenatal health, the U.S. government has warned that such genomic research and the associated genomic datasets could easily be repurposed for military applications, underscoring the potential dual-use nature of such studies.88 A 2024 report by the U.S. House Select Committee on Strategic Competition between the United States and the Chinese Communist Party revealed thousands of instances when Chinese affiliates leveraged ostensibly civilian, dual-use research to advance the PLA’s defense and technological innovation efforts.89
In this case, the PLA General Hospital in Beijing and the Third Military Medical University in Chongqing both played crucial roles in the 2011 clinical trials for the NIFTY test, working alongside BGI to expand the range of genetic abnormalities the test could detect. In 2018, BGI leveraged a PLA supercomputer to reanalyze NIFTY data, focusing on virus prevalence, mental illness indicators, and genetic characteristics of Tibetan and Uyghur minorities.90 The NIFTY test’s privacy policy, which permits data sharing when “directly relevant to national security or national defense security” in China, raises serious concerns that Chinese military or intelligence services could gain access to this data by simply demanding it from BGI, potentially leading to its use in military or state-security research or operations.91
Finally, BGI facilitates Chinese military collaboration with international partners as demonstrated by BGI’s co-hosting of events like the 15th International Congress on Genomics in Wuhan in 2020. The event featured a blend of prominent Chinese speakers, including BGI co-founder Yang Huanming, alongside researchers from several PLA institutions, such as the PLA Academy of Military Science, the PLA Army Military Medical University, and the 302nd PLA Hospital, as well as CAS researchers.92 Also present were prominent European geneticists, researchers, and public health experts, as well as an American Nobel laureate in chemistry.93
This mix of military and academic participants underscores how BGI functions as a veneer for the PLA, providing the Chinese military with cover to engage with global partners and institutions under the guise of civilian research, thereby blurring the lines between BGI and China’s military apparatus.
BGI’s Involvement in Human Rights Violations and Public Security
BGI is not just a partner to the PLA but also a key player in China’s broader biometric surveillance regime, which aims to expand the government’s control over its citizens. As the U.S. Government has alleged, the company plays an integral role in enabling the Chinese government’s repressive measures against ethnic minorities, solidifying its status as a backbone of state-led human rights abuses.
In July 2020, the U.S. Department of Commerce sanctioned BGI affiliates Xinjiang Silk Road BGI and Beijing Liuhe BGI by adding them to the Entity List for “engaging in or enabling” human rights violations and abuses as part of “China’s campaign of repression, mass arbitrary detention, forced labor and high-technology surveillance against Uyghurs, Kazakhs, and other members of Muslim minority groups in the Xinjiang Uyghur Autonomous Region (XUAR).”94 These affiliates were specifically cited as conducting genetic analyses that furthered the Chinese government’s repression of these ethnic minorities.95
Beyond BGI’s work in Xinjiang, the company’s subsidiary, Forensic Genomics International (FGI), has supported China’s domestic security apparatus, the Ministry of Public Security (MPS), in creating a vast national database for forensic identification.96 Since 2017, the MPS has aimed to compile DNA data from 5 to 10 percent of China’s male population, purportedly for law enforcement. However, like BGI’s work in Xinjiang, this ostensible “public security database” includes DNA from individuals without criminal records and even minors, raising significant human rights concerns.97
Affiliate Spotlight — MGI Tech
Although now a nominally independent entity, MGI Tech Co. Ltd. was founded in 2016 as BGI’s manufacturing arm before spinning off in 2022. The company develops and produces genomic sequencing devices, equipment, and reagents for scientific research and medical treatments. MGI has delivered thousands of genetic sequencers to over 70 countries and is planning a global expansion, including possible entry into the U.S. market with low-cost gene sequencers for hospitals.98 This would not only broaden MGI’s access to global health infrastructure and data networks — potentially bolstering China’s military research capabilities — but could also increase international dependencies on China for critical healthcare technologies.
Though established just eight years ago, MGI has quickly transcended its startup status and is now valued at over $16 billion.99 BGI’s founder, Wang Jian, retains a 47 percent stake in MGI, ensuring BGI’s continued influence over its strategic direction.100 Like BGI, MGI’s rapid rise has been accelerated by substantial capital infusions and policy support from the Chinese government — a connection that MGI did not even attempt to obscure, at least initially.
For example, MGI’s investment disclosures reference the Chinese government’s policies to “promote scientific research innovation,” including the provision of subsidies and tax exemptions to China’s biotechnology industry.101 The company touts these policies as proof that investing in MGI is a safe investment that has the government’s backing.
MGI’s investors include several CCP-affiliated funds, such as CITIC GoldStone Fund Management Co. Ltd., Shanghai Orient Securities Capital Investment Co. Ltd., and the National Social Security Fund.102 These funds have channeled capital into industries critical to China’s military-civil fusion strategy. For example, CITIC GoldStone Fund, a subsidiary of a state-owned investment bank, maintains deep ties to China’s military-industrial complex, including investments in companies like Xian TianHe Defense Technology, which manufactures reconnaissance command-and-control systems for the Chinese military.103
Historically, the Chinese government has leveraged state-backed funds, like the National Social Security Fund, to invest in companies developing cutting-edge technologies that have both military and civilian applications — an approach criticized by the Office of the U.S. Trade Representative (USTR) as aimed at dominating “technologies that may later become critical to key military systems.”104 These and other state-controlled investments underscore Beijing’s view of MGI as a strategic asset aligned with the state’s goals of advancing military capabilities and technological dominance.
Moreover, the relationship between MGI and China’s National GeneBank exemplifies how the Chinese government’s financial largesse and market manipulation policies operate in practice. According to MGI’s investment disclosures, the company is a supplier to China’s GeneBank, benefitting from a lucrative, government-backed contracting process that allows MGI to bid for sales at below-market rates.105 These market-distorting GeneBank contracts act as quasi-subsidies, providing MGI with guaranteed revenue from the Chinese government.
Similarly, China’s 2021 “Buy China” policy, formalized under Order 551 by the Chinese Ministry of Finance and the Ministry of Industry and Information Technology, mandates that Chinese institutions prioritize purchasing domestically produced high-tech equipment, such as DNA sequencers and mass spectrometers — all key products made by MGI.106 This policy puts foreign competitors at a disadvantage, enabling MGI to expand its domestic market share. MGI itself acknowledges that these policies drive “domestic substitution,” the replacement of foreign products with Chinese alternatives, thereby positioning the company for eventual dominance in the global DNA sequencing industry.107
Key Excerpts from MGI’s Investment Disclosures (with English Translation)108
Source: http://static.sse.com.cn/disclosure/listedinfo/announcement/ c/new/2022-08-23/688114_20220823_2_0XT0qsIl.pdf
MGI also benefits from its deeply intertwined relationship with its former parent company, BGI. According to MGI disclosures from 2021 and 2023, MGI serves as both a vendor and supplier to BGI, procuring essential materials and equipment for its own business while simultaneously providing specialized services and support to BGI.109 Beyond generating millions of dollars annually for MGI, these contracts reinforce MGI’s deep integration within BGI’s supply chain, which reinforces MGI’s investor appeal and, in turn, the two companies’ contributions to China’s national security and development goals.
Excerpt from BGI 2023 Investment Disclosures110
关联方 Affiliated party |
关联交易内容 Related transaction content |
本期发生额 Amount incurred in the current period |
获批的交易额度 Approved transaction amount |
是否超过 交易额度 Exceeded transaction amount |
上期发生额 Amount incurred in the previous period |
---|---|---|---|---|---|
MGI | 采购物料、设 备、接受服务
Purchase materials, equipment, and receive services |
90,434,881.12 | Part of group with 8 others
845,060,000 |
否 | 132,179,596.45 |
华大智造
(MGI Manufacturing) |
采购物料、设 备、接受服务
Purchase materials and equipment and receive services |
4,583,067.39 | Part of group with 8 others
845,060,000 |
否 | 19,938,091.31 |
MGI Americas | 采购物料、设备
Purchase materials and equipment |
7,287,244.48 | Part of group with 8 others
845,060,000 |
否 | N/A |
华大智造
(MGI Manufacturing) |
提供服务、销售设备、试剂
Provide services, sell equipment, and reagents |
1,815,112.54 | N/A | N/A | 2,028,864.47 |
Note: All of these investment disclosure line items are for MGI-related entanglements. The disclosure document does explain why some line items name MGI in English, whereas others list MGI in Chinese characters.
Amid growing U.S. government scrutiny of BGI’s involvement in human rights abuses, MGI has moved to publicly downplay its connection with BGI. In 2022, after Washington placed several BGI subsidiaries on the Commerce Department’s Entity List for facilitating the Uyghur genocide, MGI announced its spin-off from BGI, raising more than $300 million for its initial public offering.111 Soon thereafter, MGI went public and listed as a separate entity on the Shanghai Stock Exchange.
In a bid to further distance itself from BGI, MGI’s chief scientific officer, Rade Drmanac, emphasized in a 2023 interview with the Financial Times, “BGI Genomics is a completely different company … It’s sort of independent, majority-owned by investors and employees.”112 These rhetorical obfuscations and regulatory maneuvers have, in essence, enabled MGI to bypass U.S. export restrictions placed on its former parent company, BGI, creating a broad loophole that undermines U.S. technology containment efforts.
China’s Academy of Sciences Connections
Like BGI, MGI maintains deep research links with CAS. For instance, MGI is a vendor to CAS’s Xi’an Institute of Optics and Precision Mechanics, supplying CAS scientists with DNA sequencers and other critical technologies for dual-use and defense-related research and development. MGI highlighted its partnerships with CAS in investment disclosures, referring to them as “established,” “stable,” and “long-term cooperative” relationships.113
MGI 2021 Investment Disclosure Excerpt (With English Translation)
Xian Institute of Optics and Precision Mechanics, Chinese Academy of Sciences |
||
---|---|---|
Page 8-1-18 | ||
技术研发及自主创新方面的主要工作 Main work in technology research and development and independent innovation |
对应的专利、专利申请、软著情况 “Corresponding patents, patent applications, software development” |
对应的核心 技术情况 “Corresponding core technology” |
发行人自主研发和优化机械流体系统,致力于不同场景的大、中、小型仪器。 发行人与中国科学院长春光学精密机械 与物理研究所合作研发,优化测序仪光电系统的分辨率和稳定性。 “The issuer independently develops and optimizes the mechanical fluid system and is committed to large, medium, and small instruments in different scenarios. The issuer cooperates with the Changchun Institute of Optics, Fine Mechanics, and Physics, Chinese Academy of Sciences to develop and optimize the resolution and stability of the photoelectric system of the sequencer.” |
专利申请76件,其中已获授权 34件; 软件著作权 11件 “76 patent applications, 34 of which have been authorized; 11 software copyrights” |
测序仪光机电系统 技术 “Sequencer opto-mechanical system technology” |
Page 8-1-184 | ||
此外,公司也已与多个国内知名的基因测序行业的非关 联方客户如北京泛 生子基因科技有限公司、安诺优达基因科技(北京)有限公司、广州嘉检医学 检测有限公司等行业客户及武汉大学、浙江大学、上海交通大学、中国科学院 等科研院所建立了稳定长期的合作关系。 |
“In addition, the company has also cooperated with many well-known non-related party customers in the gene sequencing industry in China, such as Beijing Genetron Gene Technology Co., Ltd., Annoroad Gene Technology (Beijing) Co., Ltd., and Guangzhou Jiajian Medical Testing Co., Ltd., etc. Customers have established stable and long-term cooperative relations with Wuhan University, Zhejiang University, Shanghai Jiaotong University, Chinese Academy of Sciences, and other scientific research institutes.” |
Source: http://pdf.dfcfw.com/pdf/H2_AN202103201474295140_1.pdf
According to an MGI press release, these partnerships have enabled CAS to leverage MGI technology, specifically MGI’s DNBelab C4 and DNBSEQ sequencing technologies, to make “major breakthroughs” in human stem cell research. Human stem cell research, while typically focused on therapeutic and regenerative medical advances, also holds significant military potential due to its capacity to enhance human resilience, tissue regeneration, and recovery from extreme conditions, such as radiation or combat trauma. These capabilities could be harnessed to develop stronger, more resilient soldiers, aligning with military goals to improve performance in harsh environments, including battlefield scenarios.114 Complementing this partnership, CAS scientists are separately working on sensitive, military-related stem cell research aimed at increasing human cells’ resistance to radiation, which CAS researchers posit could “lead to super-tough soldiers who could survive nuclear fallout.”115
CAS has also purchased other specialized MGI products, like the DNBSEQ-G99 sequencer and the MGIEasy Stool Microbiome DNA Extraction Kit, to enhance its ability to conduct precise, high-throughput genomic research.116 These devices enable large-scale genetic research, facilitating faster discoveries that could accelerate CAS’s advancements in civilian and military biotechnology.
MGI has also conducted specialized training sessions for CAS scientists on DNA nanoball sequencing technology, which can sequence millions of DNA fragments in parallel to enable rapid, cost-effective analysis of large genetic datasets. Like MGI’s DNBSEQ-G99 sequencer, the precision and efficiency of MGI’s nanoball technology make it suitable for military applications, including large-scale data analysis or bio-surveillance, underscoring its potential role in dual-use research. Additionally, MGI has formalized its research collaboration with CAS through memoranda of understanding that outline joint research in areas such as immunology and infectious disease, both of which have significant implications for PLA-led biosecurity-related initiatives.117
Military-Civil Fusion University Partnerships
Beyond its partnerships with CAS and BGI, MGI also maintains research collaborations with several Chinese universities that are integral to China’s military-civil fusion strategy.118 These ostensibly civilian universities are heavily influenced by the CCP, which directs academic research and technological innovation toward military objectives through targeted funding, strategic partnerships, and direct oversight. According to MGI’s investment disclosures, these partner universities include:
- Wuhan University (武汉大学, or WHU): WHU maintains close ties to China’s military, describing itself as “a university with a strong reputation in the defense science and technology field.”119 WHU hosts four PLA defense laboratories, including the People’s Liberation Army Cryptography Administration Bureau Cryptography Research Collaborative Innovation Centre (解放军密码管理局密码研究协同创新中心), and other Chinese government-funded and directed entities suspected of carrying out cyberattacks for China’s military.120
- Zhejiang University (浙江大学, or ZU): ZU hosts three PLA defense laboratories specializing in computer simulations, high-performance computing, and control science.121 ZU is also engaged in defense-related cybersecurity research, with funding support from the Ministry of State Security (MSS), China’s primary civilian intelligence agency.122
- Shanghai Jiao Tong University (上海交通大学, or SJTU): SJTU maintains at least three PLA defense laboratories focusing on materials science, naval architecture, and hydrodynamics.123 SJTU’s School of Information Security Engineering is notable for its connections to the PLA, with key faculty members, including the dean, having served in the PLA. SJTU is also associated with PLA Unit 61398, a notorious cyber-espionage unit implicated in numerous cyberattacks against the United States. Furthermore, SJTU contributes to the PLA Navy’s development of offshore defense operations, showcasing its integral role in maritime research.
All three universities are also active participants in the China Human Proteome Organization (CNHUPO), established in 2002 by CAS and the PLA’s (U.S.-sanctioned) AMMS to strengthen China’s genomic and proteome-related research.124 A proteome is the set of proteins expressed by a genome, and advances in proteomics offer insight into human physiological functions, which could be harnessed for military applications, such as developing precision-targeted biological agents or ultramicro-scale destructive weapons. He Fuchu, the former head of the PLA’s Academy of Military Sciences who wrote about the importance of the PLA developing “brain weapons,” serves as CNHUPO’s honorary chairman.
CNHUPO’s mission includes efforts to assist Chinese “government departments in formulating development plans for human proteomics” research in China as well as to “organize and participate in international human proteomics research programs.”125 CNHUPO’s members include researchers from BGI, CAS, and the PLA as well as representatives from other military-civil-fusion focused universities, such as Peking University, Sichuan University, Shanghai Jiao Tong University, and Fudan University.126 CNHUPO’s members also include representatives from Nanjing University of Science and Technology — one of China’s “Seven Sons of National Defense,” a group of seven universities conducting research on the PLA’s behalf that are subject to U.S. Department of Commerce export restrictions.127
Harbin Institute of Technology (哈尔滨工业大学) and other PLA-related Research Initiatives
MGI also maintains a “major sales contract” with the Institute of Bioinformatics at the Harbin Institute of Technology (HIT). HIT is another one of the Seven Sons of National Defense.128 HIT’s areas of focus include biomedical engineering, nuclear technology, combustion, power engineering, and electronic propulsion — all critical to China’s military modernization. HIT also operates a specialized Military-Civil Fusion Research Institute in Beijing (哈尔滨工业大学军民融合研究院).129 The U.S. Department of Commerce added HIT to its Entity List in 2020, citing its efforts to acquire U.S. technology for the PLA’s missile program.130
Excerpt from 2022 MGI Investment Disclosure
School | AKAs or other Affiliates | |||
---|---|---|---|---|
Harbin Institute of Technology | Institute of Bio information, Harbin Institute of Technology |
|||
“正在顾行的重大销售合同 截至 2021年 12月 131日,发行人与署户己签署且正在履行的重大销售合同” “Major sales contracts under review. As of December 31, 2021, major sales contracts signed and being performed by the issuer and customers.” |
||||
销售方 /Seller | 客户 / Name | 合同金额 / Contract Amount in Millions | 合同内容/What is Contract | 签署时间 / Time of Signing |
发行人 Issuer |
哈尔滨 工业大学,生物信息基数研究院 “Institute of Bio information. Harbin Institue of Technology” |
3.760.65 57 37.6065 million yuan |
试剂.仪器销售 Sales of reagents and instruments |
2021.2 |
Source: http://static.sse.com.cn/disclosure/listedinfo/announcement/c/new/2022-08-23/688114_20220823_2_0XT0qsIl.pdf
The full scope of HIT’s biotechnology research is unclear. However, HIT researchers have used MGI’s MGISEQ-T7 gene sequencers for government-sponsored genomic projects, including the HIT-led ‘100,000 Genomes Project.’131 Launched in 2017, this project aimed to sequence the genomes of 100,000 Chinese nationals, some potentially without their knowledge or consent. Participants were chosen by Chinese authorities, according to Wang Yadong, chief director of the project.132 In 2018, then MGI President Duncan Yu emphasized how the T7 sequencer provided a “huge boost to national genome projects,” specifically citing the 100,000 Genomes Project.133
The risks posed by MGI’s partnership with HIT, and by extension the PLA and Ministry of Public Security, are hardly theoretical. HIT teams have published research regarding the institute’s contributions to mass, provincial-level police-run DNA databases in Tibet as well as provincial-level anti-trafficking DNA databases and male ancestry investigation systems.134 These studies have targeted men, women, children, and religious minorities for DNA collection outside of any ongoing criminal investigation.135 Such programs serve as an integral part of the party-state’s repression of the Tibetan people, according to the U.S. Department of State, including enabling genomic surveillance to facilitate human rights abuses.136
More broadly, according to an unclassified bulletin from the U.S. National Counterintelligence and Security Center, “The PRC [China] has a documented history of exploiting DNA for genetic surveillance and societal control,” including the collection, via Chinese national-level programs, to obtain DNA samples, fingerprints, iris scans, and blood types from Chinese citizens. 137 This information is then incorporated into centralized and searchable databases used by Chinese authorities.
Beyond Tibet, Western non-governmental organizations, including Human Rights Watch, have documented how Chinese security services have leveraged national genome programs similar to the 100,000 Genomes Project to enable state surveillance against the Uyghurs and other ethnic minorities. In China’s Xinjiang province, for example, DNA from Uyghurs has been forcibly collected under the guise of public health initiatives and benign-sounding research programs, only to be used for oppressive surveillance measures.138
Other PLA-affiliated research initiatives and institutes also utilize MGI sequencers for military-related research, according to PLA-published research papers. For example, PLA officials at the PLA’s General Hospital — one of China’s leading military medical institutions — use MGI’s MGISEQ-2000 sequencer technology to conduct cancer and tumor-related research.139 While such research may sound benign, like other dual-use research, it has direct warfighting implications. More specifically, by predicting, preventing, and treating these types of medical ailments, more warfighters can stay on the battlefield, and more support personnel can continue maintaining combat power and increasing battle success rates during conflict.
PLA officials being briefed on MGI’s MGIUS-R3 portable ultrasound diagnosis system, 2019. Source: https://www.sohu.com/a/303911665_623347
For example, in the context of potential nuclear warfare or operations involving radiation exposure, understanding and mitigating the effects of cancer and tumor growth could be critical for maintaining the health and operational readiness of military personnel. Moreover, cancer and tumor research could also be relevant in the context of biological warfare. If adversaries were to deploy biological agents designed to induce cancer or other long-term health effects, the PLA could leverage research like this to develop countermeasures or treatments.140 Such possibilities place MGI at the heart of China’s military-medical complex, reinforcing its role in advancing the PLA’s capabilities in both conventional and unconventional warfare.
A cursory review of known published genomic and biomedical research reveals dozens of instances in which PLA researchers and, in some cases, HIT researchers have used MGI equipment for genetic research projects involving topics like bloodstream pathogens, stem cells, and pneumonia. A small sample includes the following papers between 2020 and 2024:
Year | Entity(s) Cited | Research Area | MGI Technology Used | Link |
---|---|---|---|---|
2020 | Ethics Committee of Chinese People’s Liberation Army General Hospital
|
Gene fusion in leukemia patients
|
MGIEasy universal DNA library kit; MGISEQ-2000
|
https://www.ncbi.nlm.nih.gov/pmc/articles/PMC7536166
|
2020 | Ethics Committee of Chinese People’s Liberation Army General Hospital
|
Gene fusion in leukemia patients
|
MGIEasy universal DNA library kit; MGISEQ-2000
|
https://www.ncbi.nlm.nih.gov/pmc/articles/PMC7536166
|
2021 | Urology Department of the Chinese PLA General Hospital; Ethics Committee of Chinese PLA Hospital
|
Fibrinogen-like Protein in clear cell renal cell carcinoma
|
MGISEQ-2000
|
https://www.ncbi.nlm.nih.gov/pmc/articles/PMC8695555
|
2022 | Ethics Committee First Medical Center of the PLA General Hospital; Funding by Artificial Intelligence Research and Development Project of the Chinese PLA General Hospital
|
Genotype and phenotype of IQSEC2 mutations
|
NanoPrep DNA Library Preparation Module; BGI MGISEQ‐2000 sequencer
|
https://www.ncbi.nlm.nih.gov/pmc/articles/PMC9577604
|
2023 | Ethics Committee of Fifth Medical Center of PLA General Hospital
|
Clinical and genomic characteristics of HmKp (emerging and highly pathogenic global health threat)
|
MGISEQ-2000
|
https://www.ncbi.nlm.nih.gov/pmc/articles/PMC9846069
|
2023 | Ethics Committee of Chinese PLA General Hospital; CAS funded | Increasing gene sequencing output
|
MGISeq-T7
|
https://www.ncbi.nlm.nih.gov/pmc/articles/PMC10078054
|
2023 | First Medical Center of the Chinese PLA General Hospital; Funding by Ministry of Science and Technology of the 13th Five-Year Plan of China
|
Cancer research
|
MGISEQ platform
|
https://www.ncbi.nlm.nih.gov/pmc/articles/PMC10024111
|
2023 | Department of Epidemiology and Biostatistics, The Sixth Medical Center of People’s Liberation Army; Biosecurity Department, Chinese People’s Liberation Army
|
Pathogens infection in bloodstream
|
MGIEasy Cell-free DNA Library Prep Kit; MGISEQ-2000
|
https://www.frontiersin.org/journals/cellular-and-infection-microbiology/articles/10.3389/fcimb.2023.1144625/full
|
2023 | First Medical Center of the Chinese PLA General Hospital
|
Cancer treatment
|
MGISEQ platform
|
https://www.thelancet.com/journals/ebiom/article/PIIS2352-3964(23)00080-4/fulltext
|
2024 | Ethical Committee of the Chinese PLA General Hospital
|
Epilepsy correlation with molecular regions
|
NanoPrep DNA Library Preparation Module; BGI MGISEQ‐2000 sequencer
|
https://www.ncbi.nlm.nih.gov/pmc/articles/PMC11109505
|
2024 | Biochemistry Department and the Endocrine Laboratory of the Chinese PLA General Hospital; Ethics Committee of the Chinese PLA General Hospital
|
Genetic connection to insulin resistance and diabetes
|
MGISEQ-2000
|
https://www.ncbi.nlm.nih.gov/pmc/articles/PMC10850558
|
2024 | Ethics Committee of the General Hospital of the People’s Liberation Army; PLA General Hospital
|
Lung cancer
|
NadPrep Plasma Cell-Free DNA Dual-Ended Molecular Tag Library Construction Kit; MGISEQ platform; MGISEQ-T7; NadPrep DNA Library Preparation Module for MGI
|
https://www.medrxiv.org/content/10.1101/2024.07.11.24310105v1.full
|
Finally, PLA officials hope to leverage MGI’s specialized technology to enhance their strategic warfighting capabilities. For instance, at the 6th Great Wall International Military Medicine Forum in March 2019, Lu Fachin, a PLA General Hospital official overseeing the Ultrasound Department, showcased MGI’s MGIUS-R3 portable ultrasound diagnosis system.141 The demonstration, attended by PLA personnel, underscored the military context. Lu emphasized that the system’s portability allows for ultrasound diagnoses on “ocean-going warships and even on battlefields,” signaling the PLA’s intent to integrate MGI’s technology into its operational warfighting capabilities.
Policy Recommendations
China’s state-driven biotechnology ambitions and the expanding influence of behemoths like BGI and MGI pose a direct threat to U.S. economic and national security. These entities are deeply entwined with the PLA’s efforts to revolutionize warfare through biotechnology while also positioning China as a dominant global biotech player. Unchecked, they could grant the CCP unprecedented leverage over U.S. markets, critical sectors, and even individual citizens through control of genomic data, access to dual-use technologies, and potential dependency on Chinese biotech supplies.
To counter these threats, the United States must integrate biotechnology into its broader defense and emerging technology strategies, recognizing the critical intersection of biosecurity, artificial intelligence, and advanced computing. Biosecurity should become a strategic priority comparable to semiconductors, artificial intelligence, and quantum super-computing technologies.
In parallel, the United States urgently needs a comprehensive strategy to safeguard against China’s exploitation of biotechnology for strategic gain. This includes restricting BGI’s and MGI’s access to U.S. markets and technology, securing sensitive data, and reducing reliance on Chinese biotech firms. By curtailing their involvement in critical U.S. sectors and limiting their access to advanced research, the United States can safeguard its own biotech capabilities and reduce its vulnerabilities.
This will require specific actions in seven broad areas:
-
Enhance Executive Branch Coordination and Oversight
- Establish a dedicated Office for Biotechnology and Emerging Technologies within the National Security Council (NSC) to coordinate U.S. government efforts on the national security implications of biotechnology advancements, ensuring a unified approach to countering threats from companies like BGI and MGI, which are heavily intertwined with foreign government interests and activities.
- Direct the U.S. Department of Defense to integrate biotechnology threats into its National Defense Strategy and Defense Planning Guidance, emphasizing the strategic risk posed by dual-use technologies in conflict scenarios.
- Increase staffing at key agencies, including the National Security Council, the U.S. Department of Health and Human Services (HHS), and the U.S. Department of Commerce, to focus on the security implications of biotechnology and to monitor foreign influence in the U.S. biotech sector.
- Increase funding, dedicated staffing, and resources for the U.S. intelligence community and U.S. Defense Department enterprises to focus on biotechnology issues.
- Establish a “Biotechnology Risk Assessment Office” within the U.S. Department of Commerce to monitor foreign investments and partnerships in the U.S. biotechnology sector, particularly those involving Chinese state-backed entities, and to provide guidance on potential risks.
-
Improve Public Reporting and Transparency
- Mandate the Office of the Director of National Intelligence (ODNI) and the U.S. Department of Defense (DoD) to produce annual classified and unclassified assessments on China’s use of biotechnology for military modernization, including the role of private companies like BGI and MGI in collaborating with state entities.
- Require the USTR to publish an annual “Biotechnology Market Access Report” detailing Chinese state-supported efforts to dominate global biotech markets and the implications for U.S. competitiveness and security.
- Mandate that any U.S. university or research institution receiving federal grants must publicly disclose partnerships or funding arrangements with Chinese biotech firms, ensuring transparency and accountability in academic partnerships.
- Establish a dedicated Congressional Biotech and National Security Task Force to monitor and respond to threats posed by foreign state-supported entities in the U.S. biotech sector, providing regular recommendations for legislative and regulatory action.
- Require the Department of the Treasury to conduct regular reviews of U.S. investments in China’s biotech sector and report any findings to the relevant congressional committees.
-
Restrict BGI’s and MGI’s Access to U.S. Market and Infrastructure
- Add MGI Tech to the U.S. Entity List, thereby restricting its access to certain U.S. technologies, as well as to the U.S. Department of Defense’s 1260H list, which documents Chinese military companies that operate in the United States.
- Conduct a comprehensive review, under U.S. Department of Commerce Office of Information and Communications Technology and Services (OICTS) authorities, to evaluate the national security risks posed by U.S. entities utilizing BGI and MGI sequencers.
- Enact targeted export controls on U.S. semiconductor technology used in MGI’s genetic sequencers, mirroring measures taken against Huawei to limit its access to critical components.
-
Enact Federal Procurement and Reimbursement Restrictions
- Strengthen federal procurement restrictions, through measures like the BIOSECURE Act or other executive action(s), to prohibit U.S. federal agencies from purchasing BGI and MGI sequencers, ensuring no federal funds support entities linked to the CCP.
- Utilize the U.S. Department of Commerce’s OICTS authorities to prohibit BGI and MGI genetic sequencers from operating in the United States, with a phased drawdown period to ensure a smooth transition in cases where BGI and MGI sequencers are currently in use..
- Introduce legislation or enact regulatory reform to limit Medicare and Medicaid reimbursements for services using BGI and MGI technology while allowing for exemptions in cases where no viable alternatives are available.
- Amend federal grant guidelines to prohibit research partnerships with BGI and MGI in sensitive biotechnology fields. Exemptions should be allowed only with strict oversight and transparency requirements.
- Require user verification before accessing U.S. government-owned and -operated databases of genetic data, prohibiting PRC entities like BGI and MGI from accessing sensitive genetic information that could be exploited for military purposes.
-
Safeguard U.S. Genetic Data and Biosecurity
- Pass data localization legislation mandating that all genetic data collected in the United States be stored and processed domestically. The law should include exemptions for international research collaborations that meet stringent security standards and incorporate transparency requirements into their data-sharing agreements.
- Limit data sharing with foreign entities of concern by directing the U.S. Department of Commerce and HHS to review existing data-sharing agreements involving U.S. genetic data and propose targeted restrictions to prevent unauthorized access by foreign entities, with exemptions for vetted academic collaborations.
- Require the U.S. Department of Defense to establish standards for a “trusted lab” program similar to the “trusted foundry” program, whereby DoD would identify key scientific instruments and components that should be sourced from non-foreign adversary countries, ensuring proper data protection of genetic data gathered by the lab.
- Establish a Biotech Risk Assessment Office within the U.S. National Institutes of Health to assess and mitigate national security risks associated with biotechnology partnerships and research.
-
Target Financial Flows and Investments
- Consider placing BGI and MGI on the Department of the Treasury’s Non-SDN Chinese Military-Industrial Complex Company (CMIC) list to prohibit U.S. persons from purchasing equity in BGI and MGI, severing financial ties between U.S. investors and Chinese military-linked entities.
- Restrict outbound U.S. capital from investing in China’s biotechnology sector, with an initial focus on genetic sequencing technology, to prevent U.S. funds from supporting advances that China could employ to harm U.S. interests.
- Require the Committee on Foreign Investment in the United States (CFIUS) to protect personal information by blocking transactions involving foreign adversaries where the acquisition would include the transfer of U.S. persons’ genetic data. The U.S. Department of the Treasury should also update CFIUS guidelines to specifically scrutinize acquisitions or partnerships involving foreign adversaries that could result in access to U.S. persons’ genetic data.
- Direct the USTR to include biotechnology in its trade negotiations with China and apply appropriate tariffs to imports from Chinese biotech firms, thereby ensuring the protection of the U.S. biotech industry.
- Pass legislation that provides incentives for U.S. biotech companies to expand their operations and research domestically, reducing dependency on foreign biotech firms.
-
Counter China’s Global Biotechnology Expansion
- Mandate that no funds allocated by the United States President’s Emergency Plan for AIDS Relief be given to labs that utilize BGI and MGI technology while allowing for exemptions in cases where no viable alternatives are available. Such measures would ensure U.S. global health initiatives are not indirectly supporting entities linked to China’s military-industrial complex.
- Require the State Department to launch a global campaign, similar to its campaign against Huawei, to urge governments to remove BGI and MGI from their medical infrastructure.
- Support trusted U.S. sequencer producers in the Global South by authorizing the United States Agency for International Development (USAID) to create a Trusted Biotech Initiative, providing financing and technical support to help countries in the Global South procure trusted U.S. genetic sequencing technology as an alternative to BGI and MGI equipment.
- Congress should direct the U.S. State Department to establish an International Biotechnology Security Forum. The State Department should lead the forum with participation from USAID and the National Security Council to coordinate policy responses with allies and partners to the risks posed by Chinese biotech expansion.
Conclusion
China’s biotechnology ambitions, backed by state-driven strategies and military-civil fusion, pose complex challenges for global security, economic stability, and human rights. As Beijing continues to leverage biotech advancements for strategic gains, the United States and its allies must adopt proactive policies to safeguard critical technologies and genomic data. Addressing these risks today will ensure the resilience and security of tomorrow’s bioeconomy.