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Sanctions Targeting China

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On 28 July 2020, the EU agreed to impose EU-wide measures to restrict the export of certain items to Hong Kong. The EU Council’s press release can be found here. These restricted goods include equipment or technology that could be used for internal repression, interception of internal communications or cyber surveillance. Like recent US and UK measures, the new EU export controls have been proposed in response to the recent HK National Security Law. Germany…

On 20 July 2020, the UK Foreign Secretary, Dominic Raab, announced that the UK will extend to Hong Kong an EU arms embargo that has applied to mainland China since 1989 (the “Arms Embargo”). This extension forms part of the UK Government’s response to the new Hong Kong National Security Law, and the increasing role that the UK Government claims China is exerting over law enforcement in Hong Kong. The Arms Embargo prohibits the export…

On July 14, 2020, President Trump issued Executive Order 13936 “The President’s Executive Order on Hong Kong Normalization” (the “Hong Kong Normalization EO”), which directs the suspension or elimination of special and preferential treatment for Hong Kong under a wide range of US laws, setting the stage for Hong Kong to be treated the same as mainland China. It also authorizes sanctions against persons involved in developing, adopting, or implementing China’s Law on Safeguarding National…

On July 14, 2020, President Trump signed into law the Hong Kong Autonomy Act  (“HKAA”) providing for the imposition of sanctions on foreign persons who materially contribute to the undermining of Hong Kong’s autonomy by the Government of the People’s Republic of China (“PRC”) and foreign financial institutions who engage in significant transactions with such foreign persons.  During a press conference announcing the signing of the HKAA, President Trump also indicated that he had signed…