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Additional Sanctions on Russia Target Mainland Chinese Military Entity

President Trump issued an executive order on 20 September authorising the implementation of certain sanctions set forth in the Countering America’s Adversaries Through Sanctions Act to further the implementation of the sanctions regime with respect to Russia. This action includes the imposition of sanctions against a mainland Chinese entity that has been met with outrage in Beijing.

Specifically, in consultation with the U.S. Treasury Department the U.S. State Department has imposed sanctions on the mainland Chinese entity Equipment Development Department and its director for engaging in significant transactions with persons on the CAATSA section 231 list of specific persons. These transactions involved Russia’s transfer to mainland China of Su-35 combat aircraft and S-400 surface-to-air missile system-related equipment.

The State Department has also added 33 additional entities or individuals to the section 231 list of specific persons for being a part of, or operating for or on behalf of, the defence or intelligence sectors of the Russian government. This action increases the number of persons identified on this list to 72. Any person who knowingly engages in a significant transaction with any of these persons is subject to mandatory sanctions under CAATSA section 231.

The State Department indicates in a 20 September fact sheet that these actions are not intended to undermine the military capabilities or combat readiness of any country, but rather to impose costs on Russia in response to its interference in the U.S. election process, its unacceptable behaviour in eastern Ukraine, and other malign activities. However, mainland China has sharply criticised this action and said the United States must “bear responsibility for the consequences” if the sanctions are not withdrawn.

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