EU sanctions against China under new human rights sanctions regime

The EU makes, one more time, use of its new human rights sanctions framework:

Having been implemented only in December 2020, the EU demonstrates its willingness to use economic sanctions to push forward its global human rights agenda. Just recently, sanctions have been imposed against Russian officials for their involvement in the imprisonment of and repression against Mr Navalny.

Today, the EU has decided to impose sanctions against four Chinese officials and an entity for their role in the allegedly large-scale arbitrary detentions of Uyghurs in Xinjiang in China. This is a remarkable move given that this is the first time the EU adopts sanctions against China since the imposition of an arms embargo (which is still in place today) following the events at the Tiananmen Square protests in 1989. 

 All these new human rights sanctions impose asset freeze measures (and travel bans) against those designated.

As a consequence, EU companies will be prohibited from making funds or any other economic resources available to such designated persons/entities which will de facto result in a ban on all commercial activities with such persons/entities and related persons/entities. While the new designations against Chinese individuals and entities do not constitute broad economic sanctions restrictions against China or the Chinese economy, EU companies are well-advised to update their compliance programs and screen their Chinese counterparties against EU sanctions lists to ensure ongoing compliance with EU sanctions.