Sanctions Profile: China

At a glance

The EU imposed an arms embargo on China (excluding Hong Kong) by a Council Declaration at the Madrid European Council on 26/27 June 1989, in response to what the EU described as the “brutal repression” taking place in China.

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Commerce Dept requests comments on latest Huawei export controls

Last week (15 May 2020), we reported that the US Commerce Department had announced amendments to the Export Administration Regulations, which will impose licence requirements on the export/reexport/transfer of US-origin software and technology to Huawei that could be used for semiconductors or computer chips. The Commerce Department has requested comments on the amendments be submitted on or before 14 July …


OFAC adds Chinese Mahan Air sales agent to terrorism sanctions

OFAC has designated China-based Shanghai Saint Logistics Ltd pursuant to E.O 13224 (counter-terrorism sanctions) for acting as a general sales agent (GSA) for/on behalf of Mahan Air. Iran’s Mahan Air was listed in 2011 under the same E.O. for supporting the regional operations of the IRGC-QF. OFAC Notice. The press release says that Shanghai Saint Logistics provided services such as …

IranIran ChinaChina

US Senate approves Uighur Human Rights Policy Act

The US Senate has passed the Uighur Human Rights Policy Act of 2020, which would authorise sanctions (asset freeze and travel ban) on Chinese officials determined to be responsible for human rights abuses in the Xinjiang Uighur region (XAR) in China. Abuses constituting sanctionable conduct under the Act include the torture, cruel/inhumane/degrading treatment, causing disappearance or mass detention, or denial …


US tightens restrictions on Huawei semiconductor exports & issues licence

The US Commerce Department’s Bureau of Industry and Security (BIS) has announced new restrictions on the export of US-origin software and technology that could be supplied to Huawei and its affiliates to design and manufacture semiconductors. The press release says that despite previous restrictions (see post and post), Huawei has “continued to use U.S. software and technology to design semiconductors, …


Hong Kong Trade Dept advises exporters on new US controls

We reported in April 2020 that the US had removed its licence exceptions for civil-end users (CIV), meaning national security-controlled items now require licences for export to civil-end users in China, Russia and Venezuela (and other D.1 countries) from 29 June 2020. The Hong Kong Trade and Industry Department has issued a circular to confirm there is no change to …


Current Sanctions



Declaration of European Council, Madrid, 26/27 June 1989