Sanctions by the Numbers: Spotlight on China

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

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

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

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

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

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.

As a research and policy institution committed to the highest standards of organizational, intellectual, and personal integrity, CNAS maintains strict intellectual independence and sole editorial direction and control over its ideas, projects, publications, events, and other research activities. CNAS does not take institutional positions on ​policy issues and the content of CNAS publications reflects the views of their authors alone. In keeping with its mission and values, CNAS does not engage in lobbying activity and complies fully with all applicable federal, state, and local laws. CNAS will not engage in any representational activities or advocacy on behalf of any entities or interests and, to the extent that the Center accepts funding from non-U.S. sources, its activities will be limited to bona fide scholastic, academic, and research-related activities, consistent with applicable federal law. The Center publicly acknowledges on its website annually all donors who contribute.