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法评 | 赵鹏丽:2025年经济制裁与贸易管制合规回顾与展望
Sou Hu Cai Jing· 2025-12-26 11:22
Core Viewpoint - The global geopolitical landscape is increasingly complex, with ongoing international conflicts, intensified strategic competition among major powers, and a surge in sanctions and export control measures, significantly raising compliance thresholds for cross-border transactions and complicating corporate compliance management [1][2]. Group 1: Overview of Global Sanctions and Trade Control Policies - The number of global sanctions and sanctioned entities is at a historically high level, indicating a trend towards institutionalization of international sanctions activities [1]. - The article outlines the core policy dynamics in the field of global economic sanctions and trade controls for 2025, focusing on major economies like the US, EU, and China [2]. Group 2: US Economic Sanctions and Export Control Policies - In 2025, the US continues to tighten economic sanctions and export controls, enhancing oversight of sensitive technologies and strategic industries while allowing for some flexibility in implementation timelines to ease short-term compliance burdens [3]. - A new "Interim Final Rule" was introduced, requiring higher standards of due diligence for the export of advanced computing integrated circuits, expanding the scope of controlled items [4]. - The introduction of the "50% ownership rule" in export controls signifies a shift from a targeted approach to a more comprehensive one, impacting multinational companies with complex ownership structures [5][6]. - The integration of economic sanctions and export controls is becoming more pronounced, with both areas increasingly serving similar strategic objectives [7]. Group 3: EU Economic Sanctions and Trade Control Policies - The EU has intensified sanctions against Russia, expanding the scope to include third-party entities that assist in evading sanctions, reflecting a more systemic approach to sanctions [8][9]. - The EU's export control policies are increasingly aligned with international multilateral frameworks, emphasizing compliance with international obligations and enhancing cooperation among member states [10][11]. - Recent updates to the EU's dual-use item control list include new technologies and materials, indicating a proactive stance in regulating sensitive technologies [12]. Group 4: UK Economic Sanctions and Trade Control Policies - The UK has strengthened its sanctions against Russia, particularly in traditional energy and emerging technology sectors, while enhancing oversight of evasion behaviors [13][14]. - The UK has revised its Export Control Order to align more closely with international export control mechanisms, reflecting a commitment to maintaining consistency with major partners [16]. Group 5: China's Economic Sanctions and Trade Control Policies - China has introduced significant policies in economic sanctions and export controls, transitioning from a defensive posture to a more proactive and strategic approach [17]. - The implementation of the "Counter-Sanctions Implementation Regulations" marks a key step in operationalizing China's counter-sanctions law [18][19]. - China has actively utilized unreliable entity lists and export control lists, indicating a more frequent and systematic use of these tools in response to foreign sanctions [21]. - Recent announcements regarding export controls on critical materials and technologies reflect a substantial upgrade in China's export control framework [22][23]. Group 6: Future Outlook on Compliance with Economic Sanctions and Export Controls - The compliance environment for businesses is expected to become more complex and multifaceted, with rising costs associated with adapting to frequently changing regulations [25]. - Companies will need to integrate compliance into their internal controls and develop robust governance frameworks to navigate the evolving landscape of international sanctions and export controls [28][29]. - The demand for legal services related to cross-border disputes and compliance strategies is anticipated to increase as businesses face heightened risks from sanctions and export controls [26][27].
速递|美国再挥"实体清单"大棒!70+中企遭精准狙击,AI芯片成核心战场
Z Finance· 2025-03-27 21:31
Group 1 - The U.S. Department of Commerce has placed over 70 Chinese entities on the "Entity List," requiring U.S. companies to obtain licenses to sell technology to them, with most applications likely to be denied [1] - Among the listed entities is Inspur, a major cloud computing group, along with six of its Chinese subsidiaries, which had previously collaborated with U.S. chipmaker Intel [1] - The Biden administration faced criticism for not including Inspur's subsidiaries in the Entity List when it was first established in 2023 [1] Group 2 - Beijing Academy of Artificial Intelligence (BAAI) is also on the list, with the U.S. not providing any evidence for its inclusion; BAAI is a leading non-profit AI research institution established in 2018 [1] - Prior to BAAI's inclusion, Washington had already targeted Zhiyuan AI in January, indicating a broader strategy against Chinese tech firms [2] - The restrictions will apply to non-U.S. companies exporting products containing U.S. technology to the listed Chinese groups, based on the "Foreign Direct Product Rule" [2] Group 3 - The Chinese Embassy in Washington has condemned the U.S. actions, accusing it of politicizing trade and technology issues under the guise of national security [2]