OFAC sanctions program

China — Xinjiang & Hong Kong Sanctions

China faces targeted sanctions related to human rights abuses in Xinjiang, the Hong Kong crackdown, and military-civil fusion. The program is not comprehensive — most US-China trade remains legal.

Program at a glance

Program codePRC-HUMAN-RIGHTS
Legal authorityUyghur Human Rights Policy Act; Hong Kong Autonomy Act; EO 13936; Military End-User List (BIS)
ScopeTargeted / China
Designation volumeApproximately 300+ SDN and entity-list designations

Who and what it targets

Xinjiang Production and Construction Corps (XPCC), entities tied to Xinjiang internment, persons involved in the Hong Kong crackdown, and Military End-User-listed firms.

Relevance to AI agents

China sanctions are targeted, not comprehensive. Agents should screen counterparties against the program and the BIS Military End-User List, but ordinary commercial trade is generally permitted.

Screening note. A counterparty program match is not always a blanket block — the program tag tells your agent how to route the hit (hard block for terrorism/embargo, review-required for sectoral, etc.). SanctionsAI returns the program code on every match.

Frequently asked questions

Is China under comprehensive sanctions?

No. Sanctions are targeted at specific human-rights and military-civil-fusion entities. Most trade remains legal.

What is the Military End-User List?

A BIS export-control list restricting exports to entities supporting military end-uses. It complements, but differs from, OFAC SDN sanctions.

Compliance disclaimer. This page is educational and not legal advice. Program scope and current general licenses must be confirmed against the live OFAC programme page and, where relevant, by a qualified professional.

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