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China/Hong Kong 

UN Sanctions 

There are no UN Sanctions against China. (Remember China holds a permanent seat on UNSC and has veto power.)   

EU Sanctions 

The basis for limited restrictive measures imposed by the EU against China could be found in the Declaration of European Council made in Madrid, 27 June 1989 ."

Following the political Declaration of the European Council made in Madrid, on 27 June 1989 in relation to the events at the Tiananmen Square protests of 1989, the EU put in place an arms embargo against China. It is notable that France and the United Kingdom interpreted these restrictions to be applicable only to lethal arms. 

U.S. Sanctions 

The issue of China is of great importance in the United States' foreign policy. A number of United States Departments deal with the issue of China in U.S. Foreign Policy.


One of the most important ones is the Department of Commerce through the Bureau of Industry and Security (BIS). For example, it was BIS's decision to add Huawei and scores of its subsidiaries to the Entity List which prohibited the export of U.S. goods and technologies to Huawei and its listed subsidiaries. Furthermore, BIS has intensified its efforts to restrict the People’s Republic of China’s ability to purchase and manufacture certain high-end chips. BIS has a dedicated page where it gathers relevant information regarding export controls on advanced computing and semiconductor manufacturing items in China.  


In parallel, the United States has increased scrutiny on inbound foreign investments in the United States. The Committee on Foreign Investment in the United States (CFIUS) is an interagency committee that has jurisdiction over such investments. One of the main areas on which CFIUS has focused is investments made by Chinese companies in the United States. 

As far as financial sanctions are concerned, actions against China could be categorized into three types: 

  1. Designation of individuals and entities in China pursuant to various programs like Global Magnitsky, Iran, Counter Narcotics Trafficking and Cybersecurity;

  2. Rolling out a new program to address the situation in Hong Kong; and

  3.  Restricting access of certain Chinese companies close to China's military to the U.S. capital 

  • More aggressive targeting of Chinese individuals and entities

The United States added Chinese persons more frequently to the SDN list. Such designations were done for various reasons and pursuant to existing programs of OFAC. For example in July 2020, Treasury designated two Chinese government entities and six current or former government officials in connection with serious rights abuses against ethnic minorities in the Xinjiang Uyghur Autonomous Region. On August 25, 2020, OFAC added one individual and one entity to the SDN under Kingpin Act list for Shipping Fentanyl to the United States. On March 2, 2020, OFAC designated two Chinese nationals involved in laundering stolen cryptocurrency under its Cyber program. OFAC also added a number of entities and individuals involved in purchasing Iranian oil. The major designation of COSCO Shipping Tanker (Dalian) which was followed by its delisting was an example of such designation. 

  • Hong Kong-related Sanctions 

In light of the passage of the Hong Kong national security law, the United States took a number of steps namely, rolling out its Hong Kong-related sanctions program. President Trump issued Executive Order 13936 on July 14, 2020, and declared a national emergency. Among other actions, the President laid the ground for asset-freezing financial sanctions as well as travel bans. A few days later on August 7, 2020, the Department of Treasury designated 11 individuals (officials in Hong Kong). Later on November 9, 2020, OFAC added 4 more names to the SDN list under the Hong Kong program. On the legislative side, congress has been active by passing two pieces of legislation: ​the Hong Kong Human Rights and Democracy Act of 2019 (HKHRDA)​​ in November of 2019 (requiring the President to impose blocking sanctions and travel bans against certain foreign persons), and Hong Kong Autonomy Act in June 2020 (requiring the president to sanction certain foreign Financial Institution among other things).

  • Chinese Military Companies Sanctions 

On November 12, 2020, President Trump issued Executive Order 13959 and declared a new national emergency to address the threat posed by the use of companies associated with China's military from the United States capital. It prohibited the U.S. persons from any transaction in publicly traded securities or any securities that are derivative of or are designed to provide investment exposure to such securities, of any Communist Chinese military company (certain exceptions apply). The task of determining which companies are Communist Chinese military companies is entrusted to the Secretary of Defense. Several Chinese companies were listed on the list published by the Department of Defense

On June 3, 2021, President Biden issued Executive Order 14032 and largely revised the sanctions program against the Communist Chinese military companies. The new program imposed a prohibition on the purchase or sale of securities issued by Chinese Military-Industrial Complex Companies (CMIC). The new E.O. made the Treasury Department in charge of naming the companies instead of the Department of Defense.  Following this change, OFAC created a separate list called "Non-SDN Chinese Military-Industrial Complex Companies List (NS-CMIC List)."

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