In an era where regulatory compliance is under intense scrutiny, the importance of a well-orchestrated response to trade and sanctions investigations cannot be overstated. An investigation may involve transactions occurring in multiple jurisdictions, laws of separate jurisdictions, and inquiries from (or disclosures to) multiple governmental authorities. Investigations may begin through an internal whistleblower or other internal discovery, which grants the company more discretion in directing the tempo and scope of the investigation. In other instances,…
On 26 December 2023, China’s Ministry of Foreign Affairs announced new sanctions measures under the Anti-Foreign Sanctions Law against the following parties for their involvement in the imposition of US restrictive measures on Chinese entities over their links to alleged human rights abuses in the Xinjiang Uygur Autonomous Region: US data intelligence firm, Kharon; Edmund Xu, research director of Kharon; and Nicole Morgret, a former human rights analyst at the Centre for Advanced Defence Studies.…
On April 12, 2023, China’s regulators on cybersecurity and product standardization, including the Cyberspace Administration of China (“CAC”), Ministry of Industry and Information Technology (“MIIT”), Ministry of Public Security (“MOPS”), Ministry of Finance (“MOF”) and the China National Certification and Accreditation Administration (“CNCA”), jointly published a Circular to announce the following changes to the licensing regimes for network products distributed in the Chinese market: Effective from July 1, 2023, the Sales Permit for Specialized Computer…
Background After two and a half years since the issuance of the Regulations on the Unreliable Entities List (“UEL Regulations”), the Unreliable Entities List Working Mechanism (“Mechanism”) headed by China’s Ministry of Commerce has for the first time designated two US aerospace and defense companies as “Unreliable Entities”. The notice issued by the Mechanism on February 16, 2023 announced the below measures against these Unreliable Entities: prohibition on import and export activities involving China; prohibition…