2021 saw enduring trade tensions between the U.S. and China.
Under the first year of the Biden administration, the U.S.
continued to take a firm stance in its foreign sanctions policies
on China. In response, China has developed its own sanctions and
export control regime as a critical legal infrastructure to counter
the foreign sanctions pressure.
Figure 1: Key sanctions and
export control actions targeting China in 2021
(Source: OFAC, BIS, CBP, public media)
In the absence of a crystal ball, a number of developments and
trends from last year can be identified that may help to navigate
the risk landscape in 2022.
Chinese companies and individuals have been increasingly
targeted by the U.S. sanctions program in the last few
years. As of the end of 2021, the number of Chinese
individuals and companies named on OFAC's SDN list and non-SDN
list amounted to 356 (increased from 67 in 2015) and 70 (increased
from 2 in 2015) respectively. The increased
