On 7 August, an article on followed the addition of 11 Chinese companies implicated in human rights abuses committed against the Uyghur population and other Muslim minorities in China — specifically using forced labour — to its Entity List which imposes export restriction controls. The additions raise the total number of Chinese entities implicated in these abuses to 45, since October of last year.  The article points out that these companies may be linked to a wider chain of companies (and need not be based in Xinjiang and emphasises the use of enhanced due diligence through the public records plays a vital role in mitigating such risks. For example, it highlights one listed company, which is an international corporation headquartered in China’s south-eastern Jiangsu Province but is a group with many of the companies that fall under that Group having their own subsidiaries making it very easy to lose track of the large corporate network. This, in turn, makes ensuring that a supply chain is compliant with US trade regulations extremely challenging.  Using public records, Sayari said that it had identified group subsidiaries in France, Hong Kong, India, Singapore and Australia, as well as an additional 26 in China.

Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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