I. In the current international environment, all entities in the production and trade chains are increasingly becoming an ecological chain of symbiosis and common prosperity, and are bound to be restricted by the relevant laws and policies of related countries such as the United States, the United Kingdom, the European Union, ASEAN, etc. While our company requires itself to comply with such laws and policies for the benefit of all partners, it also requires our partners (including suppliers, purchasers, etc.) to abide by such laws and policies for their own and our company's benefit. To further illustrate the necessity, our company lists (only some, and we will supplement from time to time) as follows:
II. The following are some cases
On May 1, 2024, the US State Department and the Treasury Department's OFAC announced through their official websites that they had imposed sanctions on more than 280 entities from Russia and third countries. Among them, the State Department imposed sanctions on more than 80 entities and individuals, and the Treasury Department's OFAC sanctioned about 200 entities. A total of 22 Chinese (including Hong Kong) enterprises were sanctioned. The reasons listed include helping Russia circumvent sanctions, selling nitrocellulose to Russia, providing support to Russian defense industrial entities, selling machine tools and advanced manufacturing products to it, and supporting the Arctic LNG 2 project in Russia, etc. The list of relevant enterprises is as follows:
1. Anyang Forging Press Numerical Control Equipment Co., LTD.
2. CFU Shipping Co Limited
3. Chengdu Keylink Wireless Technology Co., LTD.
4. Chip Space Electronics Co., LIMITED
5. Chongqing Zongshen Aero Engine Manufacturing Co LTD
6. Finder Technology LTD
7. Hengshui Heshuo Cellulose Co., LTD.
8. Hengshui Yuanchem Trading Limited
9. HK Hengbangwei Electronics Limited
10. IPM LIMITED (a.k.a. B&W CONSULTING)
11. JINMINGSHENG TECHNOLOGY HK CO LIMITED
12. Juhang Aviation Technology Shenzhen Co., LTD.
13. Mornsun Guangzhou Science and Technology Co LTD
14. PIXEL DEVICES LIMITED (a.k.a. PIXEL DEVICES LTD)
15. RG SOLUTIONS LIMITED
16. Shvabe Opto-Electronics Co., LTD.
17. SILVER TECHNOLOGY LIMITED
18. Tulun International Holding Limited
19. Wuhan Global Sensor Technology Co., LTD.
20. WUHAN TONGSHENG TECHNOLOGY CO., LTD.
21. Yantai Iray Technology Co LTD
22. Zhongcheng Heavy Equipment Defense Technology Shandong Group Co., LTD.
On June 13, 2024, the United Kingdom announced a sanctions list against Russia, involving a total of 21 suppliers from China, Israel, Kyrgyzstan and Turkey. These new sanctions mainly target ammunition, machine tools, microelectronics and logistics suppliers to the Russian military, among which there are 5 Chinese enterprises.
1. Anhui Sino Machinery Co., LTD
2. Hengshui Yuanchem Trading Limited, Hebei
3. Hengshui Heshuo Cellulose Co., Ltd., Hebei
4. Wuhan Tongsheng Technology Co. Ltd., Hubei
5. Hengbangwei Electronics Limited, Hong Kong
III. As an extension of the first point, list some sanctions and export control regulations of some countries or regions for learning and compliance:
1. UK Bribery Act 2010
(Full text link: https://www.legislation.gov.uk/ukpga/2010/23/contents);
2. UK Russia (Sanctions) (EU Exit) Regulations 2019
(Full text link: https://www.legislation.gov.uk/uksi/2019/855/contents);
3. US Export Administration Regulations
(Full text link: https://www.bis.gov/regulations)
4. etc.
IV. As an extension of the first point, here we suggest and remind our customers to take the following measures:
1. Understand the sanctions policies and export control regulations of G7 member countries such as the United Kingdom and the United States and the European Union, and always pay attention to changes in relevant regulations;
2. Pay attention to risk assessment when conducting foreign trade, conduct due diligence on trading partners and trading entities, and identify risks in advance;
3. Strengthen the training of company employees on foreign-related risk awareness and transaction precautions;
4. Review and monitor the product supply chain to ensure that the behavior of partners or intermediaries complies with relevant regulations and prevent implication on the enterprise.
5. Other measures.
The above content is first required to be followed by our partners as a prerequisite for cooperation, and it also constitutes a friendly reminder and expectation to enable the long-term healthy development of our customers and our company.