On March 22, 2021, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned two Chinese government officials for “serious human rights abuses” against ethnic minorities in the Xinjiang Uyghur Autonomous Region of China. In a brief press statement, the Director of OFAC stated, “Chinese authorities will continue to face consequences as long as atrocities occur in Xinjiang …. Treasury is committed to promoting accountability for the Chinese government’s human rights abuses, including arbitrary detention and torture, against Uyghurs and other ethnic minorities.” This action was taken by the United States in conjunction with the European Union, United Kingdom and Canada, which imposed sanctions on these individuals and others.

The two officials sanctioned are: (i) Wang Junzheng, the Secretary of the Party Committee of the Xinjiang Production and Construction Corps (XPCC), and (ii) Chen Mingguo, Director of the Xinjiang Public Security Bureau (XPSB). OFAC has previously sanctioned other Chinese officials over concerns in the Xinjiang region over human rights abuses (see Update of August 3, 2020). The Department of Commerce has also placed a number of Chinese companies on the Entity List (see Federal Register notices of July 22, 2020 and June 5, 2020) in an effort to combat China’s campaign of repression, mass arbitrary detention, forced labor and high-technology surveillance against Uyghurs, Kazakhs and other members of Muslim minority groups in the Xinjiang region.

As a result of this action, these officials have been placed on OFAC’s Specially Designated Nationals (SDN) List and all property and interests in property of the individuals, and of any entities that are owned 50% or more by them, that are in the United States or in the possession or control of U.S. persons must be blocked and reported to OFAC. Unless authorized by a general or specific license issued by OFAC, or otherwise exempt, all transactions by U.S. persons or within (or transiting) the United States that involve any property or interests in property of these designated persons is generally prohibited.

U.S. exporters and importers should remain mindful of the July 1, 2020 multi-agency advisory that warns U.S. businesses of potential supply chain risks involving the Xinjiang region (see Update of July 2020). U.S. businesses, individuals, academic institutions, service providers, investors and others operating in this region could face significant reputational, economic and legal risk if sufficient due diligence of supply chain activity in China is not conducted.