Hong Kong’s Technology Lifeline to Russia

As the war in Ukraine continues into its second year, Moscow has intensified its campaign to strike Ukrainian targets with strategic bombers, lethal drones, and cruise missiles.¹ To cut off Russia’s access to the critical components required to manufacture these weapons, the United States and its partners have imposed a wide array of sanctions against Russia’s defense industrial base. Despite Western sanctions, foreign-made technology continues to find its way into Russia’s war machine. Russia’s most consequential partner, China, has extended a critical helping hand to an increasingly isolated Russia, funneling over $500 million worth of microelectronic components needed to manufacture military gear into Russia’s defense industrial base in 2022 alone.²

While China’s support for Russia is widely reported, Hong Kong’s substantial contributions to Russia’s war efforts are less known. Recent reports have identified Hong Kong as a prominent node in Russia’s illicit procurement network, acting as a transshipment hub for diverting Western-made microelectronic components to companies affiliated with the Russian military.³ Since Russia’s invasion of Ukraine, Hong Kong has doubled its integrated circuits exports to around $400 million worth of semiconductors in 2022, second only to China and far exceeding any third country in the volume of semiconductor trade with Russia.⁴ Many of these transactions violate U.S. export control regulations against Russia, and multiple individuals and entities operating from Hong Kong have been sanctioned for their involvement in the Russian military’s procurement network.⁵

Hong Kong’s complicity in sanctions busting is not merely a byproduct of being one of the busiest shipping hubs in the world; it is a direct consequence of Hong Kong’s increased subservience to China, now that Beijing has wiped out the last vestiges of autonomy in the special administrative region. In today’s Hong Kong, the government follows Beijing’s orders in virtually all matters of governance, particularly for issues with geopolitical salience. High levels of semiconductor trade between Hong Kong and Russia, as well as the Hong Kong government’s public scorn for Western sanctions, have made Hong Kong’s allegiance clear: it sits firmly in the camp of an emerging China-Russia axis.

Russia’s Semiconductor Supply Chain

Numerous reports indicate that despite sweeping Western sanctions, Russia’s defense industrial base has successfully established alternative routes to import dual-use components needed for manufacturing military equipment.⁶ Lacking scalable domestic substitutes, Russia relies on foreign-made microelectronic components to produce a range of military gear, including weapons like drones and cruise missiles.⁷ Examining Russian weapons captured in Ukraine, the Royal United Services Institute (RUSI) discovered in August 2022 that the majority of microchip components in Russian systems originated from the United States, East Asia, and Western Europe.⁸ Tracing the supply chain of microelectronics, RUSI concluded that “third-country transshipment hubs and clandestine networks operated by Russia’s special services are now working to build new routes to secure access to Western microelectronics.”⁹

A leader in low-end microchip manufacturing and the world’s top chip importer, China is now the foremost supplier of semiconductors to Russia. In 2022, as Western countries restricted technology supply, Russia’s semiconductor imports from China skyrocketed, jumping from $200 million in 2021 to well over $500 million in 2022, according to Russian customs data analyzed by the Free Russia Foundation.¹⁰ Importantly, the Sino-Russian technology trade involves not only Chinese-made components but also products manufactured by top U.S. chipmakers such as Intel, Advanced Micro Devices, and Texas Instruments. Nikkei Asia recently reported that exports of U.S. chips from Hong Kong and China to Russia increased tenfold between 2021 and 2022, reaching about $570 million worth.¹¹ By one figure, China and Hong Kong together accounted for nearly 90 percent of global chip exports to Russia in the period between March and December 2022.¹²

China’s support to Russia’s war effort is unsurprising. The two countries are aligned in their ambition to undermine the U.S.-led international order. Before the war, Beijing and Moscow declared that the countries’ friendship had “no limits,” and a Chinese top diplomat has recently reaffirmed that Sino-Russian relations are “reaching new milestones.”¹³ The summit between Chinese President Xi Jinping and Russian President Vladimir Putin in Moscow, held in March 2023, further consolidated the importance of this strategic partnership. Less examined is Hong Kong’s role in Russia’s technology supply chain.

While most countries have begun to recognize Hong Kong’s loss of autonomy following the passage of the Hong Kong national security law in 2020, the city is still often treated as separate from China in economic and trade data. This is as much a matter of convention as an acknowledgement of Hong Kong’s unique function to China: the former British colony is highly integrated into the global economy, serving as China’s window to the world. Hong Kong’s connectivity with the world has allowed unscrupulous actors to hide their footprints amid the busy international flows. Its prominence in Russia’s technology supply chain exemplifies this point. Researchers and journalists have found that some Hong Kong–based companies have diverted significant quantities of Western-made electronic components to Russia since its invasion of Ukraine.¹⁴ Macro-level data bear out Hong Kong’s importance to Russia’s defense-industrial base (although export statistics vary depending on the source). The Free Russia Foundation found that Hong Kong doubled its semiconductors and integrated circuits exports to around $400 million in 2022, putting it second only to China’s $500-million-plus exports.¹⁵ China and Hong Kong far exceed any third country in the volume of microchips trade with Russia.

Beijing Pulling the Strings

What explains Hong Kong’s prominence in Russia’s effort to sustain war in Ukraine? The most immediate factor is Beijing’s increased control over all aspects of the governance of Hong Kong. Historically, Western countries treated Hong Kong’s exports as sufficiently autonomous from China’s strategic objectives.¹⁶ In 1992, the United States and other former Coordinating Committee for Multilateral Export Controls (COCOM) members designated Hong Kong a “cooperating country,” affirming that it possessed the necessary elements of an effective licensing and enforcement system.

The transfer of sovereignty to China in 1997 prompted fears that Hong Kong would become a hub for technology diversion into China and other so-called rogue states like North Korea. The principle of “one country, two systems” was designed to assuage such anxiety by promising that Hong Kong would continue to exercise independent authority over export controls, which the government interprets as a trade matter, meaning that it falls under the legal bounds of Hong Kong’s autonomy.¹⁷ Under the United States-Hong Kong Policy Act of 1992, after China took over Hong Kong’s sovereignty in 1997, the “United States should continue to support access by Hong Kong to sensitive technologies controlled under [COCOM] for so long as the United States is satisfied that such technologies are protected from improper use or export.”¹⁸ As a result, Hong Kong was eligible to import, without license, extensive categories of U.S.-controlled dual-use items and was eligible for license exceptions for some categories. In contrast, China was required to obtain a license to procure items controlled for U.S. national security and was eligible for a license exception only when the destination was verified as civil end users.¹⁹ A 1997 report by the U.S. General Accounting Office (now Government Accountability Office) characterized Hong Kong favorably for having demonstrated “excellent cooperation with the United States on export enforcement activities, including sharing of information and cooperation on investigations, searches, and seizures of suspected illegal shipments.”²⁰

However, as Hong Kong’s autonomy has steadily eroded, so has its willingness to comply with Western export control regimes, especially when they contradict China’s strategic interests. Today’s Hong Kong scorns Western sanctions against Russia. After Russia invaded Ukraine in February 2022, Western governments launched a frantic campaign to seize the assets of Russian oligarchs, hoping to deter elites from aiding Russian war efforts. In sharp contrast, Hong Kong’s Chief Executive John Lee, himself sanctioned by the United States for suppressing the 2019 protests, said that the government would not recognize U.S. sanctions against Russia, asserting that Hong Kong has no legal obligation to enforce “unilateral sanctions” after a Russian oligarch’s yacht was spotted in Hong Kong in October 2022.²¹ Furthermore, Hong Kong has become a top alternative for Russian companies shut out of Western financial capitals like New York and London. As Bloomberg reported in October 2022, a number of major Russian companies, including state-owned enterprises, have sought to engage with Hong Kong law firms to help anchor them in a “friendlier jurisdiction.”²² A local research group later found that between February and October 2022, the number of Russia-affiliated businesses registered in Hong Kong reached thirty-five, more than doubled from the same period in 2021.²³

Does the China Factor Really Matter?

It is no coincidence that Hong Kong’s noncompliance with Western sanctions has been simultaneous with Hong Kong’s deteriorating political autonomy. Xi is determined to exploit Hong Kong’s advantages to further his strategic ambitions, even if it means tarnishing Hong Kong’s international reputation.

Some might argue that Beijing’s increased grip on Hong Kong has had little effect on the city’s attitude toward Western sanctions. After all, Hong Kong was already a major transshipment hub, even prior to signs of serious deterioration of its autonomy. The volume of dual-use items transshipped through Hong Kong has contributed to conflict and terrorist activities that had less strategic salience to China than the war in Ukraine has. For example, transshipped U.S. electronics components and devices were used to build improvised explosive devices that were deployed against coalition forces in the Iraq war, a conflict for which China largely stayed on the sidelines.²⁴

Additionally, Hong Kong’s status as a busy transshipment port to locations around the world naturally increases the risks of illicit technology diversion. Transshipment is notoriously hard to detect from trade data because it requires visibility throughout multiple stages in the supply chain. Due to the sheer volume of transshipment occurring via Hong Kong, it is hard for export control officials to conduct preshipment screening or postshipment checks. It is particularly easy to set up front companies in jurisdictions like Hong Kong. As a manager at a leading U.S. semiconductor distributor explains, “there are many formless shell companies and small trading companies in Hong Kong that serve as receptacles for secondary sales. . . . If you spot one illegal trade, they can just change their name or use their other trading companies’ names.”²⁵

It becomes even more challenging to distinguish between transshipment to sanctioned entities and transshipment to legitimate importers if the importing country has a large existing market for dual-use goods. According to trade data compiled by the Observatory of Economic Complexity, Hong Kong has consistently been the world’s top importer of electrical machinery and electronics since 2004.²⁶ In the global trade of integrated circuits, for instance, Hong Kong imported 24.3 percent (or $162 billion) of the world’s trade in 2020, exceeding even China’s $114 billion imports.²⁷

But this line of argument fails to account for the big picture. While the problem of illicit trade has historically bedeviled Hong Kong, the government’s open defiance against Western sanctions since the Ukraine war signals its commitment to a deliberately lax approach to export controls. The sizeable flow of technology from Hong Kong to Russia is the result of an active political choice. The reactions from other major transshipment hubs, such as Singapore and the United Arab Emirates (UAE), illustrate that it is possible to stem the flow of technology to Russia if there is political will to do so. U.S. authorities have long recognized the prominence of Hong Kong, Singapore, and the UAE in illicit trade networks. The three major transshipment ports reacted to Western sanctions regimes against Russia differently according to their geopolitical interests.

Despite being a U.S. security partner, the UAE has joined other Middle Eastern states in refusing to participate in Western sanctions regimes. It has abstained from voting in favor of a United Nations Security Council (UNSC) draft resolution condemning Russian aggression in Ukraine,²⁸ allowed Russian oligarchs to launder money through its ports, spurned Washington’s request that it pump more oil to diminish Russian oil revenue by reducing global oil price, and refused to crack down on the reexporting of electronic components to Russia.²⁹ Data show that exports of electronic parts from the UAE to Russia increased sevenfold within a year to almost $283 million in 2022, while microchip exports rose by fifteen times to $24.3 million from $1.6 million in 2021. The Gulf country also sold 158 drones worth a total of $600,000 to Russia.³⁰

If the UAE has allowed tech trade with Russia to flourish out of self-interest, Singaporean leaders have pursued a different calculus—choosing to align themselves more closely with the U.S. position.³¹ In a statement made on February 28, 2022, Singapore’s foreign minister said, “Russia’s invasion of Ukraine is a clear and gross violation of the international norms and a completely unacceptable precedent. This is an existential issue for us.”³² In a rare move, the city-state announced sanctions against Russia that included “four banks and an export ban on electronics, computers and military items,” becoming the only Southeast Asian country to impose sanctions against Russia in the absence of binding UNSC approval.³³ According to the Free Russia Foundation, Singapore is among the countries that have most dramatically curtailed trade with Russia.³⁴ In terms of semiconductors and integrated circuits, Singapore was the ninth-biggest exporter to Russia in 2021. A prominent node in the global supply chain, Singapore accounts for 19 percent of the global share of semiconductor equipment, providing Russia in 2019 with approximately $10.6 million worth of semiconductor devices.³⁵ This has shifted since Russia’s full-scale invasion of Ukraine, when Singapore chose to side with Western sanctions regimes. In 2022, exports of semiconductors from Singapore to Russia collapsed dramatically down to a negligible level.³⁶

Geopolitical interests explain both the UAE’s spike and Singapore’s plummet in exports to Russia. These cases illustrate that changes in economic and technology ties with Russia are largely driven by the countries’ stances on the Ukraine war, which are in turn motivated by their geostrategic calculus. Similarly, Hong Kong’s permissive stance toward trading technology with Russia is a product of Beijing’s geopolitical calculations. Repeatedly, Hong Kong officials have demonstrated that they have no ability to defy Beijing’s will and no interest in doing so, even if it means alienating the international community. If China is determined to help Russia wage war against Ukraine by extending a technology lifeline, Hong Kong will follow suit.

Still Asia’s World City?

In July 2020, recognizing Hong Kong’s loss of autonomy, former U.S. president Donald Trump announced that Hong Kong “is no longer sufficiently autonomous to justify differential treatment in relation to the People’s Republic of China.” The United States would “suspend or eliminate different and preferential treatment for Hong Kong.”³⁷ Shortly after, the Commerce Department began rescinding Hong Kong’s export licensing privileges, such as by equalizing the availability of license exceptions for Hong Kong and China. In December, the department declared that it would treat exports to Hong Kong as destined for China, effectively ending Hong Kong’s preferential status in the U.S. export control system. Some of the United States’ closest partners have implemented similar changes.³⁸

Stripping away Hong Kong’s preferential trading status is a good first step in stopping the leakage of sensitive goods to China and its autocratic allies. But unilateral action from the United States is not enough. While these restrictions have slowed the movement of export-controlled goods in and out of Hong Kong—for example, the Commerce Department detected a 17.4 percent decline in shipments under a Bureau of Industry and Security license exception between 2020 and 2021—Hong Kong on the whole remains relatively interconnected with the global economy.³⁹

Russia’s permanent seat on the UNSC has guaranteed the failure of any efforts to push for comprehensive UN sanctions and continues to provide political cover for jurisdictions like Hong Kong and the UAE to resist pressure to cooperate with Western countries. This, combined with Hong Kong’s posture as a busy shipping port that is inherently difficult to monitor, has given the Hong Kong government plausible deniability when accused of supporting Russia’s war machine. There is no clear answer to how Western countries should deal with nonaligned countries in the Global South that wish to stay out of what they perceive as a great power competition, but one thing should be clear: Hong Kong falls outside the nonalignment camp, since it has taken the side of the emerging China-Russia axis.

A wider recognition of Hong Kong as a geostrategic asset of Chinese statecraft is in order. Hong Kong’s government is investing large sums in a charm offensive to rehabilitate its international image and attract international business. In a promotional video for the government’s $2 billion HKD “Hello Hong Kong” campaign, Lee claimed, “Hong Kong is now seamlessly connected to the mainland of China and the whole international world.”⁴⁰ But the findings presented in this article show that a portrayal of Hong Kong as a neutral trading hub connecting East and West no longer holds up. Western leaders should be aware of the geopolitical costs of Hong Kong’s position as a major center of global trade and the advantages that subsequently accrue to Beijing.

Correction: This piece has been edited to reflect that Chief Executive John Lee said Hong Kong would disregard U.S. sanctions on Russia, not those on China.

Notes

¹ Susie Blann, “Russia Hits Targets Across Ukraine with Missiles, Drones,” AP News, February 10, 2023, https://apnews.com/article/russia-ukraine-kharkiv-eb242b1e9d1894e5616bc2da55173d88.

² Sebastian Bienkowski et al., “Effectiveness of U.S. Sanctions Targeting Russian Companies and Individuals,” Free Russia Foundation, January 2023, 48, https://www.4freerussia.org/wp-content/uploads/sites/3/2023/01/frf-sanctions-web.pdf.

³ James Byrne et al., “Silicon Lifeline: Western Electronics at the Heart of Russia's War Machine,” Royal United Services Institute, August 8, 2022, https://static.rusi.org/RUSI-Silicon-Lifeline-final-updated-web_1.pdf; Steve Stecklow, David Gauthier-Villars, and Maurice Tamman, “The Supply Chain That Keeps Tech Flowing to Russia,” Reuters, December 13, 2022, https://www.reuters.com/investigates/special-report/ukraine-crisis-russia-tech-middlemen/; and James Byrne et al., “The Orlan Complex: Tracking the Supply Chains of Russia’s Most Successful UAV,” Royal United Services Institute, December 2022, https://static.rusi.org/SR-Orlan-complex-web-final.pdf.

⁴ Bienkowski et al., “Effectiveness of U.S. Sanctions,” 50.

⁵ Some examples of Hong Kong semiconductor companies sanctioned by the United States include EMC Sud Limited, King-Pai Technology HK Co Ltd, Sinno Electronics Co Ltd, and World Jetta (HK) Logistics Limited. See Byrne et al., “Silicon Lifeline,” 50, 53; and “Treasury Targets Russian Financial Facilitators and Sanctions Evaders Around the World,” U.S. Department of Treasury, April 12, 2023, https://home.treasury.gov/news/press-releases/jy1402.

⁶ Bienkowski et al., “Effectiveness of U.S. Sanctions”; Byrne et al., “Silicon Lifeline”; Byrne et al., “The Orlan Complex”; Stecklow et al., “The Supply Chain”; Ian Talley and Anthony DeBarros, “China Aids Russia’s War in Ukraine, Trade Data Shows,” Wall Street Journal, February 4, 2023, https://www.wsj.com/articles/china-aids-russias-war-in-ukraine-trade-data-shows-11675466360; Nathaniel Taplin, “How Russia Supplies Its War Machine,” Wall Street Journal, March 10, 2023, https://www.wsj.com/articles/russia-ukraine-tech-chips-exports-china-f28b60ca; Andrew David, Sarah Stewart, Meagan Reid, and Dmitri Alperovitch, “Russia Shifting Import Sources amid U.S. and Allied Export Restrictions: China Feeding Russia's Technology Demands,” Silverado Policy Accelerator, January 2023, https://cdn.sanity.io/files/0wfzc71x/production/6745ea42c21d65d6709231e0e7767bd5de57469b.pdf; and Maxim Chupilkin, Beata Javorcik, and Alexander Plekhanov, “The Eurasian Roundabout: Trade Flows Into Russia Through the Caucasus and Central Asia,” European Bank for Reconstruction and Development, February 2023, https://www.ebrd.com/publications/working-papers/the-eurasian-roundabout.

⁷ Byrne et al., “Silicon Lifeline.”

⁸ Byrne et al., “Silicon Lifeline.”

⁹ Byrne et al, “Silicon Lifeline,” 5.

¹⁰ Bienkowski et al., “Effectiveness of U.S. Sanctions,” 48.

¹¹ Riho Nagao et al., “Special Report: How U.S.-made Chips Are Flowing into Russia,” Nikkei Asia, April 12, 2023, https://asia.nikkei.com/Business/Tech/Semiconductors/Special-report-How-U.S.-made-chips-are-flowing-into-Russia.

¹² Ana Swanson, “China’s Economic Support for Russia Could Elicit More Sanctions,” New York Times, February 22, 2023, https://www.nytimes.com/2023/02/22/us/politics/china-russia-sanctions.html; and “Russia Semiconductor Imports Dashboard: Pre- and Post-Invasion Trends,” Silverado Policy Accelerator, updated February 10, 2023, https://silverado.org/news/russia-semiconductor-imports-dashboard-pre-and-post-invasion-trends/. For more statistics on China’s and Hong Kong’s contribution to Russia’s war effort, see Talley and DeBarros, “China Aids Russia’s War”; Taplin, “How Russia Supplies”; and David, Stewart, Reid, and Alperovitch, “Russia Shifting Import Sources,” 14.

¹³ Nectar Gan and Simone McCarthy, “Putin and China’s Top Diplomat Pledge to Strengthen Ties Ahead of Ukraine War Anniversary,” CNN, February 22, 2023, https://www.cnn.com/2023/02/22/china/china-wang-yi-moscow-ukraine-intl-hnk/index.html.

¹⁴ For example, in 2022, a Hong Kong–based company called Asia Pacific Links provided 25 percent of semiconductor imports by SMT-iLogic, a Russian company that has diverted millions of dollars’ worth of Western-made electronic components to a manufacturer of Russian military drones. Another Hong Kong company, Agu Information Technology—established in April 2022, after the start of the Ukraine war—shipped expensive, advanced Intel chips to Russia for a total value of about $18.7 million from September to December 2022. A number of small and medium-sized Hong Kong enterprises were also implicated in exporting U.S. chips to Russia. See Byrne et al., “The Orlan Complex,” 20; Bienkowski et al., “Effectiveness of U.S. Sanctions,” 32; and Nagao et al., “Special Report.”

¹⁵ Bienkowski et al., “Effectiveness of U.S. Sanctions,” 50.

¹⁶ In fact, Hong Kong was the destination of the very first semiconductor factory outside of the United States. In 1963, U.S. company Fairchild Semiconductor, the leading manufacturer of integrated circuits at the time, opened its first overseas assembly factory in Kowloon Bay, Hong Kong. See Chris Miller, Chip War: The Fight for the World's Most Critical Technology (New York: Scribner, October 4, 2022), 53.

¹⁷ “Hong Kong’s Reversion to China: Effective Monitoring Critical to Assess U.S. Nonproliferation Risks,” U.S. General Accounting Office, May 1997, 11, https://www.gao.gov/products/nsiad-97-149.

¹⁸ “S.1731 - United States-Hong Kong Policy Act of 1992,” U.S. House of Representatives, accessed May 11, 2023,  https://uscode.house.gov/view.xhtml?path=/prelim@title22/chapter66&edition=prelim.

¹⁹ U.S. General Accounting Office, “Hong Kong’s Reversion,” 6.

²⁰ U.S. General Accounting Office, “Hong Kong’s Reversion,” 4.

²¹ Greg Torode and Donny Kwok, “Russian Oligarch's Luxury Yacht Departs Hong Kong Port,” Reuters, October 20, 2022, https://www.reuters.com/world/russian-oligarchs-luxury-yacht-departs-hong-kong-port-2022-10-20.

²² Kiuyan Wong, “Russian Firms Turn to Hong Kong in Bid to Avoid Sanctions,” Bloomberg, October 10, 2022, https://www.bloomberg.com/news/articles/2022-10-10/russian-firms-turn-to-hong-kong-in-bid-to-avoid-sanctions.

²³ Oiwan Lam, “What Is Hong Kong Role in Russia’s Sanction Evasion?,” GlobalVoice, December 21, 2022, https://globalvoices.org/2022/12/21/what-is-hong-kong-role-in-russias-sanction-evasion.

²⁴ “Export Controls: U.S. Agencies Need to Assess Control List Reform’s Impact on Compliance Activities,” U.S. Government Accountability Office, April 2012, 18, https://www.gao.gov/assets/gao-12-613.pdf.

²⁵ Nagao et al., “Special Report.”

²⁶ “Electrical machinery and electronics” is denoted by Harmonized System (HS) code 85.

²⁷ “Integrated Circuits,” Observatory of Economic Complexity, accessed March 26, 2023, https://oec.world/en/profile/hs/electrical-machinery-and-electronics. This category of items is denoted by four-digit HS code 8542.

²⁸ Frederic Wehrey, “The Impact of Russia’s Invasion of Ukraine in the Middle East and North Africa,” Carnegie Endowment for International Peace, May 19, 2022, https://carnegieendowment.org/2022/05/19/impact-of-russia-s-invasion-of-ukraine-in-middle-east-and-north-africa-pub-87163.

²⁹ Wehrey, “The Impact of Russia’s Invasion.”

³⁰ Sam Fleming et al., “West Presses UAE to Clamp Down on Suspect Russia Sanctions Busting,” Financial Times, March 1, 2023, https://www.ft.com/content/fca1878e-9198-4500-b888-24b17043c507.

³¹ Xirui Li, “Why Singapore Has Chosen to Impose Sanctions on Russia,” Diplomat, March 9, 2022, https://thediplomat.com/2022/03/why-singapore-has-chosen-to-impose-sanctions-on-russia.

³² Vivian Balakrishnan, “Minister for Foreign Affairs Dr Vivian Balakrishnan’s Ministerial Statement on the Situation in Ukraine and its Implications,” Singapore Ministry of Foreign Affairs, February 28, 2022, https://www.mfa.gov.sg/Newsroom/Press-Statements-Transcripts-and-Photos/2022/02/20220228-Ministerial-Statement.

³³ Chen Lin and Anshuman Daga, “Singapore Sanctions Russia Over ‘Unprovoked Attack’ on Ukraine,” Reuters, March 5, 2022, https://www.reuters.com/world/asia-pacific/singapore-sanctions-russia-over-unprovoked-attack-ukraine-2022-03-05.

³⁴ Bienkowski et al., “Effectiveness of U.S. Sanctions,” 3.

³⁵ Ariel Cohen, “Western Sanctions Aim to Cut Off Russia from Critical High-Tech Goods,” Forbes, February 28, 2022, https://www.forbes.com/sites/arielcohen/2022/02/28/western-sanctions-aim-to-cut-off-russia-from-critical-high-tech-goods/?sh=88704e26d8b4.

³⁶ Bienkowski et al., “Effectiveness of U.S. Sanctions,” 50.

³⁷ “The President’s Executive Order on Hong Kong Normalization,” White House, July 14, 2020, https://trumpwhitehouse.archives.gov/presidential-actions/presidents-executive-order-hong-kong-normalization.

³⁸ In 2020, the United Kingdom and the European Union imposed greater restrictions of “sensitive” goods to Hong Kong, effectively extending to Hong Kong an EU arms embargo that has applied to China since the 1989 Tiananmen Massacre. Germany followed the United States’ example in declaring it would “treat the territory in the same way as the rest of the People's Republic of China” in regulating the exports of military equipment as well as dual-use goods. See Dominic Raab, “Hong Kong and China: Foreign Secretary’s Statement in Parliament,” UK Foreign and Commonwealth Office, July 20, 2020, https://www.gov.uk/government/speeches/hong-kong-and-china-foreign-secretarys-statement-in-parliament; “Council Conclusions on Hong Kong,” 9872/1/20 Rev 1, Council of the European Union, July 24, 2020, https://www.consilium.europa.eu/media/45225/st09872-re01-en20.pdf; and “EU Restricts Exports to Hong Kong Over China Security Law,” Deutsche Welle, July 29, 2020, https://www.dw.com/en/eu-restricts-exports-to-hong-kong-over-china-security-law/a-54359734.

³⁹ “U.S. Trade with Hong Kong: 2021,” U.S. Department of Commerce, https://www.bis.doc.gov/index.php/documents/technology-evaluation/ote-data-portal/3018-2021-statistical-analysis-of-u-s-trade-with-hong-kong/file.

⁴⁰ Hillary Leung, “Video: HK$2bn ‘Hello Hong Kong’ Campaign Gives Away 500,000 Plane Tickets to Help Reboot Tourism,” Hong Kong Free Press, February 2, 2023, https://hongkongfp.com/2023/02/02/hk2bn-hello-hong-kong-campaign-gives-away-500000-plane-tickets-to-help-reboot-tourism.