![]() ![]() company may be designated on the anti-sanctions list, and the Chinese party on the SDN List may sue that U.S. company that stops supplying products to a Chinese party designated on the SDN List may be deemed to be aiding or abetting in the implementation of a discriminatory restrictive measure therefore, the U.S. The new law prohibits all entities/individuals, whether foreign or domestic, from implementing or assisting in the implementation of foreign sanctions against Chinese citizens and entities. The Anti-Foreign Sanctions Law imposes conflicting obligations for multinational companies with subsidiaries in China, including Hong Kong and Macao. The Anti-Foreign Sanctions Law also does not provide a foreign party with any cure period for rectification or right to apply for removal from the list, which are available under the UEL Provisions. It is possible that a foreign party may be designated by both the UEL and the anti-sanctions list under the Anti-Foreign Sanctions Law if its actions are captured by both laws. While the UEL Provisions focus on international economic and trade activities, the Anti-Foreign Sanctions Law applies more broadly to include activities with political nature. The new law appears to have overlapping application with the UEL Provisions, as shown in the comparison table below. ![]() Treasury Department’s Specially Designated Nationals (SDN) List. The measures are similar to sanctions imposed by the United States and other governments and appear to be akin to designation on the U.S. prohibit or restrict commercial transactions, cooperation, and other activities with entities or individuals within the territory of China and.seizing and freezing assets, tangible or real property within the territory of China.refusal to issue visas, deny entry, visa cancellation or deportation.The State Council may penalize individuals/entities on the anti-sanctions list by taking one or more of the following measures: entities that are controlled, established, or operated by such individuals/entities.entities where such individuals serve as senior management personnel and.senior managers or actual controllers of such entities.the spouses and immediate relatives of such individuals.In addition, the anti-sanctions list may expand beyond such individuals/entities to include: According to Article 4 of the new law, if an individual or entity is directly or indirectly involved in the formulation, decision making, and/or implementation of the sanctions imposed by foreign countries, that individual or entity may be included in an anti-sanctions list. ![]()
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