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Sanctions Targeting China

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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…

The US Administration has taken a series of actions in recent days to tighten US export controls for Hong Kong and to sanction Chinese government officials in response to the decision of the Chinese Communist Party (“CCP”) to impose a new national security law for Hong Kong. Most significantly, these actions put Hong Kong on a par with China with respect to license exception eligibility under the US Export Administration Regulations (“EAR”) by suspending all…

On June 17, 2020, the President signed the Uyghur Human Rights Policy Act of 2020 into law. The law authorizes the President to impose sanctions on persons, including Chinese government officials, determined to be responsible for certain human rights violations and abuses committed against Muslim minority groups in China or elsewhere. The law requires the administration to sanction those individuals by blocking their assets and declaring them ineligible for visas or admission to the United…