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Ivy Tan

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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.…

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…

More than one year since China’s new Export Control Law (“ECL”) became effective, the Ministry of Commerce (“MOFCOM”) has finally released the long-awaited Regulations on Dual-use Item Export Control (“Draft Regulations”) draft, for public comments on 22 April 2022. The Draft Regulations can be found here: 关于《两用物项出口管制条例(征求意见稿)》公开征求意见的通知 (mofcom.gov.cn). We highlight below the key takeaways from our review of the Draft Regulations. 1. Scope of items subject to controls Although the Draft Regulations relate specifically to the…

On 14 March 2022, the Monetary Authority of Singapore (“MAS”) issued the following 2 notices that are legally binding on all financial institutions regulated by the MAS (including banks, finance companies, insurers, capital markets intermediaries, securities exchanges, payment service providers and digital payment token service providers): Notice SNR-N01 Financial Measures in Relation to Russia Notice SNR-N02 Financial Measures in Relation to Russia – Non-prohibited Payments and Transactions Notice SNR-N02 sets out the general sanctions measures against…