Litigation

Sanctions Roundup Third Quarter 2021

Shearman & Sterling LLP

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1 CHINA Since his inauguration, President Biden has signaled that the United States will maintain efforts to combat perceived aggressions by the People's Republic of China, particularly as they relate to democracy and human rights. After six months of significant sanctions measures, the Administration this quarter took a relatively light approach. U.S. regulators together released two separate advisories to guide the public in their dealings with potential ties to China. Meanwhile, seven PRC officials were sanctioned for allegedly implementing anti- democratic measures in Hong Kong. Finally, Huawei CFO Meng Wanzhou returned to China after striking a deal with the Department of Justice. US Takes 'Whole of Government' Approach to Warn of the Risks of Connections to Xinjiang and Hong Kong For the past two years, successive administrations have sought to counter the PRC's perceived human rights abuses in Xinjiang and encroachments on Hong Kong's autonomy, imposing widespread sanctions on a host of PRC entities and officials. This quarter, actions against specific entities and individuals were reduced in lieu of "whole of government" advisories alerting U.S. persons worldwide to the risks of pursuing China-related business. The first such advisory focused on potential links to Xinjiang in global supply chains. On July 13, the Office of the U.S. Trade Representative and U.S. Departments of State, Commerce, Homeland Security, Treasury, and Labor released an updated "Xinjiang Supply Chain Business Advisory." The notice details the numerous risks to any businesses with exposure in their operations and supply chains to entities engaged in reported human rights abuses in the Xinjiang Uyghur Autonomous Region. The advisory supplements a similar advisory released last year and encourages businesses with any nexus to Xinjiang to undertake enhanced due diligence to identify links to sanctioned entities and ensure supply chains are free of forced labor concerns. The notice specifically

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