China incl. Hong Kong

Information as of: 31st May 2022

Latest Updates
UN  
US
EU  
UK
 On 19th May 2022 the UK amended the Export Control Order 2008 by introducing The Export Control (Amendment) Order 2022 and the amendments establish new export and transfer restrictions where the Secretary of State has informed the relevant person that non-listed dual-use goods, software or technology are, or may be, intended for use by military forces, para-military forces, police forces, security services or intelligence services of an embargoed destination; and add China, Hong Kong and Macao to the list of destinations that are embargoed and subject to transit controls for military goods.
Arms Embargo
UN
US Arms embargo applies to mainland China (since 1989) and Hong Kong (since 29 Jun 2020).
EU Arms embargo applies to mainland China sice 1989.
UK
Arms embargo applies to mainland China sice 1989. On 20 Jul 2020 UK extended arms embargo to include Hong Kong.  The Export Control (Amendment) Order 2022 
Further Details
UN
US On 29 Jun 2020, the US arms embargo was extended to include Hong Kong. With effect from 14 Jul 2020, pursuant to EO 13936, sanctions were imposed on officials , including Carrie Lam, for undermining Hong Kong's autonomy and restricting the freedom of expression or assembly of the citizens of Hong Kong. On the same day, 14 Jul 2020, the Hong Kong Autonomy Act (HKAA) was signed into law and provides for the imposition of asset freezes and travel bans on designated entities, in addition to providing for secondary sanctions on Foreign Financial Institutions that engage in significant transactions for those entities designated. On 23 Dec 2020, Hong Kong was removed as a separate destination from China under the Export Administration Regulations (EAR). Hong Kong will now be treated as China and will be subject to the same licence requirements and exceptions as China. Effective 11 Jan 2021 EO 13959 prohibits US persons from purchasing or investing in any securities, including stocks, shares, funds, or other financial products in Chinese companies operating directly or indirectly in the US that OFAC or the Defence Dept have identified as “Chinese military companies” or their subsidiaries, regime listed as 'Chinese Military Companies Sanctions' by OFAC. On the 3 June 2021 the US issued E.O. “Addressing the Threat from Securities Investments that Finance Certain Companies of the People's Republic of China”, which amends E.O. 13959 by expanding the scope to include  prohibitions on investments in Chinese surveillance technology firms and companies operating in the defence sector WEF 2 August 2021. The national emergency declared under EO 13936 was extended until 14 Jul 2022.  OFAC extended the National Emergency EO13959  for a further year, until 12th November 2022, pursuant of EO14032On the 23 December 2021 Biden signed into law HR 6256, the Xinjiang Uyghur Forced Labour Prevention Act which will come into effect on the 21st June 2022. The Act imposes an import ban on goods that have been mined, produced or manufactured in Xinjiang, China, or otherwise by a entity listed under the Act. The ban is intended to prevent the import of goods that have been produced by forced labour. On the 16 February 2022 OFAC added the "Issuance of Chinese Military-Industrial Complex Sanctions Regulations" to implement E.O. 13959 (and amended by  “Addressing the Threat from Securities Investments that Finance Certain Companies of the People's Republic of China”).
EU Arms embargo applied to mainland China since 1989.
UK
Arms embargo applied to mainland China since 1989. On 20 Jul 2020, the UK extended the arms embargo to Hong Kong, including the ban on crowd control equipment and any items that might be used for internal repression, lethal weapons and their components, military aircraft and helicopters, war vessels, armoured fighting vehicles and other weapons platforms. On 19 May 2022 the UK amended the Export Control Order 2008 by introducing The Export Control (Amendment) Order 2022 and the amendments establish new export and transfer restrictions where the Secretary of State has informed the relevant person that non-listed dual-use goods, software or technology are, or may be, intended for use by military forces, para-military forces, police forces, security services or intelligence services of an embargoed destination; and add China, Hong Kong and Macao to the list of destinations that are embargoed and subject to transit controls for military goods.
This information has been collated by the International Underwriting Association of London and is intended as a guide only. The IUA does not accept any liability for the accuracy of this information.
This publication is intended to convey only general information about sanctions legislation and associated insurance coverage. It is not, and is not intended to be, a complete statement of the law relating to this area. It should not be relied on or be used as a substitute for legal advice in relation to any particular set of circumstances. Accordingly, IUA does not accept any liability for any loss which may arise from reliance on this information.