Sanctions by the Numbers: Comparing the Trump and Biden Administrations’ Sanctions and Export Controls on China

SDN Designations

Under both the Trump and the Biden administrations, the United States predominately used the SDN List to impose sanctions on Chinese persons engaged in activities supporting other adversaries of the United States. This reflects a common concern about the People’s Republic of China’s (PRC’s) ties with other authoritarian states such as Iran, Russia, and North Korea. A key distinction is the sharp increase in Russia-related SDN designations during the Biden administration following Russia’s invasion of Ukraine in 2022 and the continued efforts of the United States and partners to target entities around the world facilitating Russian sanctions and export control evasion.

The Trump administration predominately used SDN designations on Chinese persons to reinforce sanctions campaigns on Iran and North Korea. It also used SDN designations to respond to rising concerns about the plight of the Uyghurs and the status of democracy in Hong Kong.

Although countering cooperation between the PRC and Iran remained a priority under the Biden administration, the focus of its economic statecraft has recently shifted to the China-Russia nexus. In the first eight months of 2024, the Biden administration added 124 Chinese persons to the SDN List due to their connections with Russia. This coincides with warnings from a series of senior U.S. officials throughout 2024 that the United States is prepared to intensify its use of sanctions on Chinese persons supporting the Russian war effort.

At the same time, the Biden administration continues to focus on using the SDN List to counter PRC support for malign Iranian activities. This has only intensified since the outbreak of the conflict between Israel and Hamas following the October 7, 2023, terror attack on Israel, contributing to a notable increase in Chinese persons being designated on the SDN List under Iran, nonproliferation, and terrorism-related sanctions authorities during the latter half of the Biden administration.

SDN designations are only one type of financial restriction. This report focuses on SDN designations as the most severe form of financial sanction, though the United States’ financial sanction toolkit has expanded over the past two administrations. As explored in prior research, both administrations implemented or proposed additional types of financial restrictions, including limited investment restrictions on companies designated as operating in China’s military industrial complex or supporting its cyber surveillance programs, as well as broader technology-based restrictions on U.S. investments in China.

Entity List Additions

Both the Trump and Biden administrations predominantly used the Entity List to respond to advances in China’s military modernization, often in combination with other forms of export controls. However, each administration prioritized different aspects of the People’s Liberation Army’s (PLA’s) modernization efforts.

During the Trump administration, the Bureau of Industry and Security (BIS) designated several Chinese entities for their support of China’s nuclear weapons, unmanned aerial vehicle (UAV), and missile programs, as well as their contributions to the country’s semiconductor and supercomputing capabilities. Notably, slightly more entities were explicitly designated for their connections to China’s nuclear weapons, UAV, and missile programs than for their connections to China’s semiconductor or supercomputing efforts. In contrast, the Biden administration focused on limiting China’s access to dual-use technologies, such as semiconductors, quantum computing, and biotechnology. Notably, on October 7, 2022, the Commerce Department unveiled sweeping export control rules aimed at curbing China’s advanced chips, artificial intelligence (AI), and supercomputing capabilities. The administration expanded these restrictions in October 2023 and is reportedly considering additional changes before the end of its term.

The Trump and Biden administrations also sought to use the Entity List to curb the flow of strategic technologies and goods from China to other authoritarian powers. The Trump administration focused on countering China-Iran ties. However, its approach was highly concentrated on Huawei: 55 of the 71 Chinese entities added to the Entity List for evading sanctions and export controls on Iran were Huawei and its China-based subsidiaries and affiliates. Additionally, Huawei and its affiliates were the only Chinese entities to receive an FDPR during the Trump administration.

Notably, the Trump administration used Entity List additions to respond to PRC gray zone tactics in the South China Sea, with 30 additions made explicitly in response to the PRC’s land reclamation activities in contravention of international law. The authors were not able to identify any Entity List additions in either the Trump or Biden administrations in direct response to gray zone activities related to Taiwan.

Over the course of the prolonged conflict in Ukraine, Entity List additions and FDPR applications have increasingly focused on Chinese entities assisting the Russian military-industrial complex and evading U.S. sanctions on Russia. As a reflection of the Biden administration’s growing concern with the cooperation among China, Russia, and Iran, it listed five persons for supplying UAV components to both Russian and Chinese military end users. It also placed 13 Chinese persons on the Entity List for supplying components for UAVs that were deployed by the Iranian military and utilized by Russia on the battlefield in Ukraine.

Conclusion

The PRC will undoubtedly remain a central focus of U.S. economic statecraft regardless of which candidate wins the upcoming election. Both a second Trump administration and a Harris administration are likely to use financial sanctions and export controls to counter China’s ties with other U.S. adversaries and its military modernization efforts. However, data from the first Trump administration and the Biden administration suggest that the activities each would target through sanctions or export controls strategies could differ substantially, and that major geopolitical events can play an important role in shifting sanctions strategy, as was evident with Russia during the Biden administration.

Terminology & Methodology

Terminology

The term “person” throughout this document denotes an individual or entity, excluding aircrafts and maritime vessels. (Entries in the Sanctions by the Numbers series prior to 2022 included aircraft and maritime vessels under the definition of “entity.”)

The Specially Designated Nationals and Blocked Persons (SDN) List is maintained by the Department of the Treasury’s Office of Foreign Assets Control (OFAC). An SDN designation represents the United States’ most stringent financial sanction, prohibiting U.S. persons from engaging in any transaction with the designated individual or entity and freezing all U.S.-based assets associated with them.

The Entity List is maintained by the Commerce Department’s Bureau of Industry and Security (BIS). It is used to restrict or prohibit the export of U.S. goods and technologies to listed persons.

Foreign direct product rules (FDPRs) are extraterritorial export controls that control the trade in foreign-made goods, if these goods are made using U.S. software or equipment.

“PRC” refers to the Chinese state. The “party” refers to the Chinese Communist Party (CCP). “China” means the entire country, inclusive of nongovernment and nonparty actors. When discussing economic activity, the default term is also “China,” to encompass the range of individuals, firms, and government entities that may be involved in economic activity.

Methodology

All U.S. government designations and delistings were drawn from the following OFAC sanctions programs: BELARUS-EO14038, CAATSA- RUSSIA, CYBER2, DPRK2, DPRK3, DPRK 4, ELECTION-EO13848, GLOMAG, IFCA, IFSR, ILLICIT-DRUGS-EO14059, IRAN, IRAN-EO13846, IRAN-EO13871, IRGC, NPWMD, RUSSIA-EO14024, SDGT, SDNTK, TCO, UKRAINE -EO13661, UKRAINE-EO13662, VENEZUELA, and VENEZUELA-EO 13850, issued from January 1, 2017, through August 30, 2024. All information regarding additional sanctions, export controls, and other economic measures from the Departments of Commerce and State were drawn from public government sources: Federal Register Notices, press releases, and the BIS Entity List. Data on the specific illicit activity associated with SDN and Entity List designations is taken from OFAC press releases and BIS Federal Register Notices.

There is some uncertainty in quantifying SDN designations by policy priority because OFAC press releases do not always discuss the sanctionable activity that leads to each designation. For instance, in a round of OFAC sanctions, there may be 100 designations, but only 50 are called out and explained in the press release. In this case, the report records “at least” 50 designations pursuant to the particular policy priority or illicit activity discussed in the press release. The authors used the justifications given by the BIS in the Federal Register Notices to determine the reason why a specific Entity List addition was made. For example, they counted persons as being placed on the Entity List for contributing to China’s military modernization efforts if the BIS explicitly stated they were listing the person for (1) providing goods and technologies to Chinese military end users/People’s Liberation Army (PLA) programs, or (2) diverting goods and technologies to China that have potential military applications.

The Center for a New American Security (CNAS) Energy, Economics & Security Program (EES) uses nationality to determine the country of an individual placed on the Specially Designated Nationals and Blocked Persons List. This, however, may not necessarily reflect the country of residence or country of origin of an individual. For example, EES would categorize a person of Syrian origin who is a Canadian citizen under “Canada.”

EES uses the physical address to determine how to categorize entities placed on the SDN List. In instances in which the entity has an address in multiple countries, the entity is labeled under each country in which it is located. For example, an entity based in China and Switzerland would be counted as both a Chinese and a Swiss entity.

Subsidiaries are listed separately on the Entity List and are therefore counted as discrete designations in this data. For instance, in 2020, the total number of designations to which a foreign direct product rule was applied is entirely attributable to Huawei Technologies and its subsidiaries. For SDN designations, subsidiaries may be listed separately or may be captured under OFAC’s 50 percent rule, which automatically applies the SDN restriction to entities in which the blocked person owns 50 percent or more.

In prior research, slightly different figures were reported for the full duration of the Trump administration. Since that publication, EES has corrected an error in its underlying methodology related to the attribution of nationality of persons on the SDN List and related to parent-subsidiary relationships on the Entity List. That methodological correction resulted in slightly different counts for the Trump administration in this publication. The Biden administration numbers also shifted, but EES has not previously published Biden numbers for the date range in this publication.

Sanctions designations often overlap with several different sanctioning authorities, including country-specific and thematic sanctions programs. In the case where a single designation is pursuant to multiple sanctioning authorities, the designation is counted once within the total designation number but attributed to each pursuant sanctioning authority. For example, if the United States designated Entity X located in China pursuant to GLOMAG and HK-EO13936, then that single designation is recorded once for the total designation of U.S. sanctions but contributes to both the GLOMAG and HK-EO13936 designation counts.

Sanctions numbers for Hong Kong and Macau are included within the total China numbers for this report.

Foreign direct product rule applications for any given year refer to all entities to which an FDPR was applied. It includes both (1) entities that had an FDPR applied at the time of their listing in the specified year, and (2) entities that were initially placed on the Entity List in a previous year but received an FDPR in the specified year.

Although the Departments of State and Treasury coordinate closely on sanctions policy and implementation and each have their own sanctions authorities, this report did not make a distinction between the two for analytic purposes. Regardless of which agency has the authority, any sanctions that resulted in persons being put on the SDN List were included in this analysis. Any sanction that did not result in placement on the SDN List were not included.

Where possible, the report noted if a sanctioned entity had made a public statement or response to their designation on one of the sanctions lists. To the knowledge of EES researchers, when Huawei and its 68 affiliates were added to the Entity List in May 2019, the company did not make a public statement or comment. However, when the Commerce Department placed an additional 46 affiliates of Huawei on the Entity List in August 2019, the company’s CEO, Ren Zhengfei, did comment on the move in remarks to the Associated Press. When an FDPR was applied to Huawei in May 2020, Guo Ping, chairman of the company’s supervisory board, responded to the move in a speech he gave at an annual company event.

Acknowledgments

The authors would like to acknowledge the CNAS Communications and Publications teams for their support, design, and edits. The authors would also like to thank Emily Kilcrease, EES senior fellow and director, and John Hughes, EES adjunct senior fellow, for their reviews of this report. This report was made possible with general support to CNAS.

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About the Authors

Rowan Scarpino is a former program administrator for the Energy, Economics, and Security team at CNAS. Prior to joining CNAS, Scarpino served as a research assistant and project assistant at the Center for Inter-American Policy & Research, where she evaluated U.S. policy impact on Venezuelan humanitarian and political crises. She has also researched human rights, atrocity prevention, and transitional justice and served in the nonprofit sector. Rowan graduated from Tulane University with dual degrees in international relations and philosophy. She also studied international justice at Leiden University College the Hague.

Eleanor Hume is a research assistant for the Energy, Economics, and Security Program at CNAS. She supports the Center’s work on American economic statecraft and geoeconomic competition between the United States and China. Before joining CNAS, Eleanor was a policy analyst at the China Economic and Strategy Initiative, part of the Project 2049 Institute. She has also worked at the German Marshall Fund and on Capitol Hill.

Eleanor graduated from George Washington University with bachelor’s degrees in international affairs and Asian studies. She also holds a master’s degree in law and diplomacy from Tufts University. Eleanor is proficient in Mandarin and lived in China for nearly two years.