December 02, 2020

Sanctions by the Numbers: Spotlight on China

By ​Francis Shin

The United States has significantly increased its sanctions designations on Chinese individuals, entities, and ships in 2020. While the United States has imposed sanctions on Chinese entities and individuals for many years, these past actions were usually part of sanctions regimes that targeted other states, such as Chinese companies trading with North Korea or Iran, or non-state actors, like criminals and drug traffickers. However, as U.S.-China relations have deteriorated over the course of 2020, the United States has directly targeted Chinese entities and individuals with sanctions. This includes naming Chinese officials associated with systemic human rights abuses and territorial aggression in the region. While the bulk of currently sanctioned Chinese individuals and companies are still primarily linked to China’s facilitation of activities from other countries, recent targeting has shifted sharply to focus on China more directly.

Total Designations against Chinese Individuals and Entities by Program Targets, 2001–2020

Source: Historical data from 2001–2020 from the U.S. Department of the Treasury’s Office of Foreign Assets Control

This graph shows the total number of designated Chinese entities from 2001 to the present, organized by sanctions program. The majority of Chinese entities sanctioned (64 percent) were designated for ties to Iran and North Korea.

Sanctions Designations of Chinese Individuals and Entities by Target, 2001–2020

Source: Historical data from 2001–2020 from the U.S. Department of the Treasury’s Office of Foreign Assets Control

After sanctioning only one Chinese official over the past 20 years, the United States has dramatically increased designations of Chinese officials since July 2020.

Sanctions Designations of Chinese Individuals and Entities

Source: Historical data from 2001–2020 from the U.S. Department of the Treasury’s Office of Foreign Assets Control

The United States significantly increased designations of Chinese actors under the Trump administration. The number of designations reached a record high in 2017, and again in 2020. Compared to the Trump administration’s recent focus on human rights violations, 93 percent of designations under the Bush administration were based on ties to terrorist groups or states on the State Sponsors of Terrorism list, while 68 percent of designations under the Obama administration were based on counterproliferation programs.

Number of Human Rights–Related Sanctions Designations of Chinese Individuals and Entities

Source: Historical data from 2001–2020 from the U.S. Department of the Treasury’s Office of Foreign Assets Control

Until 2017, no human rights–related sanctions were imposed on any Chinese entities. However, the number of human rights–related sanctions has sharply increased over the past year as U.S.-China relations have deteriorated. These designations are primarily related to the state-led repression in Xinjiang and Hong Kong.

Crime-Related Sanctions Designations of Chinese Individuals and Entities

Source: Historical data from 2001–2020 from the U.S. Department of the Treasury’s Office of Foreign Assets Control

Over the past two decades, the number of designations of Chinese entities for organized crime and drug trafficking has been inconsistent. However, as with the recent rise in Chinese designations under human rights authorities, the Trump administration has noticeably increased designations of Chinese entities for criminal activities over the past several years as bilateral relations have cooled. The United States imposed a total of 19 designations in the past three years. In contrast, over the course of 16 years, the Bush and Obama administrations made only seven and eight designations, respectively.

Methodology

The following sanctions programs were included: NPWMD, SDGT, 561List, IFSR, SDNTK, SYRIA, DPRK2, DPRK3, DPRK4, TCO, CAATSA-RUSSIA, IRAN, IRAN-EO13846, IRAN-13871, IFCA, CYBER2, GLOMAG, and HK-EO13936. In cases where the sanctions program was designed to be open instead of tailored to target a specific state or non-state entity, determining if the entities were based in China and/or directly tied to the Chinese government demonstrated that Chinese entities were the primary targets. For example, the Union Development Group is listed as being based in Cambodia but was designated under GLOMAG because it is a Chinese state-owned enterprise. As a result, its designation was included in this analysis.

This is the fourth installment in the Sanctions by the Numbers series. Click here to read the first installment on U.S. sanctions designations and delistings by Johnpatrick Imperiale, here to read the second installment on global distribution of U.S. sanctions, and here to read the third installment on Iran sanctions, both by Abigail Eineman.

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Authors

  • ​Francis Shin

    Former Intern, Energy, Economics, and Security Program

    Francis Shin is a former Joseph S. Nye intern for the Energy, Economics, and Security Program at the Center for a New American Security (CNAS)....

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