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Sanctions Targeting China

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Hong Kong controls dual-use items under the Import and Export Ordinance (Cap. 60) and its corresponding subsidiary legislation, the Import and Export (Strategic Commodities) Regulations (Cap. 60G) (“IESCR”). On 17 September 2021, an order to amend the list of strategic commodities under relevant schedules to the IESCR came into effect. The amendments aim to align Hong Kong’s control list with international non-proliferation regimes, including the Wassenaar Arrangement. The Trade and Industry Department has provided guidance…

On June 3, 2021, President Biden issued Executive Order 14032, “Addressing the Threat from Securities Investments that Finance Certain Companies of the People’s Republic of China” (the “CMIC EO”). This amends and replaces Executive Order 13959 (“EO 13959”) and revokes Executive Order 13974 (“EO 13974”) that restricted investments in certain “Communist Chinese Military Companies” (“CCMCs”). The main changes implemented by the CMIC EO and related public guidance are to (1) change the group of targeted…

Effective March 22, 2021, Canada has imposed new sanctions against four Chinese officials and a Chinese entity under the newly enacted Special Economic Measures (People’s Republic of China) Regulations (the “Regulations”), in response to the alleged human rights situation in Xinjiang. Becoming a listed person under the Regulations has two noteworthy consequences. First, listed persons who are individuals are considered inadmissible to Canada under the Immigration and Refugee Protection Act. Second, the Regulations effectively impose…

On 22 March 2021, the UK Government added four individuals and one entity to the Global Human Rights financial sanctions regime, in relation to alleged human rights violations taking place in Xinjiang, China. Four Chinese government officials and a Xinjiang security body have been added to the UK sanctions list and to the Office of Financial Sanctions Implementation’s consolidated list of financial sanctions targets. These measures were announced in coordination with Canada and the United…