US Sanctions and Export Controls Against China: A Complex Web of Restrictions

The United States has employed various sanctions and export control measures against China to address national security and foreign policy concerns. These measures are enforced through several lists, which are updated regularly.

Key Lists Used for Sanctions and Export Controls

Specially Designated Nationals (SDN) List

• Maintained by the Office of Foreign Assets Control (OFAC) within the U.S. Department of the Treasury
• As of December 2022, contains over 7,400 entries
• Includes Chinese companies involved in human rights abuses in Xinjiang, such as Hikvision and Huawei

Entity List

• Also maintained by OFAC
• Restricts exports to certain entities based on national security concerns or other factors
• As of December 2022, contains over 1,500 entries

Entities Targeted by the United States

• Chinese companies involved in human rights abuses in Xinjiang, such as Hikvision and Huawei
• Individuals and entities for their involvement in the crackdown on Hong Kong’s civil society and mass arrests of anti-government protesters

Additional Tools Used to Address Concerns with China

• Technology restrictions
• Investment controls
• Controls on U.S. investment in China, which is under consideration in Congress and the administration

Future Directions for US Sanctions Policy

• The United States is likely to explore new types of economic restrictions short of an SDN listing
• Whether the United States can build a broader consensus among allies and partners on the expanded use of these tools remains an open question
• Doing so will be critical for ensuring the long-term durability and political legitimacy of the U.S. strategy