To:
peter.brien@slaughterandmay.com
keith.pogson@hk.ey.com
charlesli@hkex.com.hk
edmond.chan@hk.pwc.com
Matt.Emsley@hsf.com
paul.k.lau@kpmg.com
Victoria.Lloyd@ropesgray.com
richard.pu@tencent.com.hk
dieter.yih@kyclaw.com
aalder@sfc.hk
cfmailbox@sfc.hk
Cc:
info@hkex.com.hk
laura.cha@hkex.com.hk
calvintai@hkex.com.hk
ferheenmahomed@hkex.com.hk
florenceleung@hkex.com.hk
bonniechan@hkex.com.hk
bho@sfc.hk
chairmanoffice@sec.gov
OFAC_Feedback@treasury.gov
Richard.Ashooh@bis.doc.gov
Re:
Grave Objection to Ant Group’s Listing Application
Dear Listing Committee and Mr. Alder,
I am writing to lodge a complaint about the listing application of Ant Group Co., Ltd. (“Ant Group”). Put bluntly, Ant Group grossly understates the materiality of risks arising from U.S. financial sanctions in the latest prospectus (dated October 27, 2020), in breach of Main Board Listing Rules and the Guidance Letter HKEX-GL101-19. This casts doubt on whether Ant Group is really suitable for listing.
Specifically, Ant Group has understated both (i) the probability of financial sanctions; and (ii) the materiality of financial sanctions (should they occur). As soon as the aforementioned factors are taken into account, Ant Group’s suitability for listing comes into question.
(A) Understated probability of U.S. financial sanctions on Ant Group
Despite noting “the recent trend of the U.S. government targeting Chinese technology companies” (p.59), Ant Group provides nothing more than passing remarks on the risks of being hit by U.S. financial sanctions. Worse still, these remarks are pointedly vague. They fail to specify the set of circumstances under which Ant Group may fall under U.S. financial sanctions given its nature of business. As such, investors are deluded into a false sense of comfort, having been denied critical information for measuring - let alone mitigating - sanctions risks arising from Ant Group.
Frustratingly, Ant Group fails to consider any of the three different scenarios of sanctions as set out in the Guidance Letter HKEX-GL101-19, namely:
(i) Ant Group is a “sanctioned target”[1];
(ii) Ant Group has engaged in “primary sanctioned activity”[2]; or
(iii) Ant Group has engaged in “secondary sanctionable activity”[3].
Scenario 1: Ant Group is a sanctioned target
Ant Group faces a heightened risk of U.S. financial sanctions at the same time when it is downplaying it. On August 6, 2020, the Trump administration issued executive orders prohibiting any transactions with TikTok and WeChat, pursuant to the International Emergency Economic Powers Act (“IEEPA”).[4][5] As a novel legal instrument against China, the IEEPA is “an incredibly expansive authority and allows the president to declare a national emergency with respect to just about anything,” according to Brian Fleming, a lawyer at Miller & Chevalier, who previously worked in the U.S. Justice Department’s national security division.[6] Known for its financial potency, the IEEPA authorizes the U.S. administration to prohibit, among others:
· any transactions in foreign exchange;
· transfers of credit or payments between, by, through, or to any banking institution, to the extent that such transfers or payments involve any interest of any foreign country or a national thereof; and
· the importing or exporting of currency or securities, by any person, or with respect to any property, subject to the jurisdiction of the United States.[7]
Barely a week after issuing the executive order, U.S. President Donald Trump hinted at a similar move against Ant Group’s substantial shareholder Alibaba. In a masterly display of disingenuity, however, Ant Group fails to make the slightest reference to the IEEPA in documenting U.S. actions against TikTok and WeChat (the latter of which suffered a 10% drop in share price on the day of announcement), or itself indeed.[8] Throughout the prospectus, there is only one single hint at the IEEPA, albeit in an entirely different context - that is, when Ant Group warns of sanctions risks for companies with ties to the Chinese military (p.58). This is a covert act of substituting realized sanctions risks facing comparable technology peers for unrealized sanctions risks facing not-so-comparable defence contractors. By doing so, Ant Group attempts to dissociate itself from its unfortunate Chinese technology peers who have fallen victim to the IEEPA.
Nor is there anything reassuring about the Trump administration’s later clarifications that the prohibitions are not on financial transactions per se but only on those relating to mobile applications of WeChat and TikTok.[9] The fact that it took the Trump administration a total of six weeks to finalize the scope of sanctions is indicative of the heavily political nature of the sanctions. Given the capacity of the Trump administration to surprise, Ant Group is gravely mistaken to assume away the risks of financial sanctions pursuant to the IEEPA without providing any plausible explanation.
Indeed, the U.S. has a myriad of reasons to impose financial sanctions on Ant Group on national security grounds. As in the case of WeChat ban, Ant Group may be accused of being “an active participant in China’s civil-military fusion” and “subject to mandatory cooperation with the intelligence services of the [Chinese Communist Party]”.[10] According to a report by RWR Advisory Group, Ant Group has raised concerns about its “military dual-use potential”, “participation in social credit system construction” through its subsidiary Zhima Credit, as well as “data collection and privacy concerns” under China’s National Intelligence Law”.[11] The key point is not whether Ant Group is actually infringing upon national security or human rights, but that it is perceived to be doing so. Perceptions of Ant Group’s subservience to the Chinese government is reinforced by none other than Jack Ma himself, founder and ultimate controller of Ant Group, who famously said in 2017, “As long as the country needs it, we are ready to dedicate Alipay to the country at any time.”
In the wake of Ant Group’s listing application, for example, the U.S. Committee on Present Danger: China (“CPDC”) has aggressively called for the “de-pegging” of the U.S. and Hong Kong dollars in retaliation - a euphemism for U.S. financial sanctions given that the currency peg itself is the prerogative of Hong Kong.[12] More directly, the CPDC warns that the escalation of U.S.-China tensions puts Ant Group “at risk of financial repercussions stemming from potential U.S. government action against these enterprises, which could harm U.S. and other investors.”[13] It is worth noting that the CPDC is an influential lobby group in the U.S. to the extent that it successfully persuaded the Trump administration to ban federal pension fund from investing in Chinese companies in May 2020.
One day before Ant Group published its prospectus, U.S. Senator Marco Rubio also introduced a bill to bar U.S. investment firms, retirement funds and insurance companies from taking stakes in Chinese companies on the Entity List overseen by the U.S. Commerce Department.[14] Marco Rubio is no ordinary congressman, having been the one who prompted the Trump administration’s investigation into TikTok.[15] As the U.S. State Department has submitted a proposal to add Ant Group to the Entity List[16], the risks of direct financial sanctions on Ant Group have multiplied.
Scenario 2: Ant Group has engaged in primary sanctioned activity
A separate time bomb is found in Ant Group’s minority interest in Megvii Technology Limited (“Megvii”). In October 2019, Megvii was added to the U.S. Entity List for “human rights violations and abuses in the implementation of China’s campaign of repression, mass arbitrary detention, and high-technology surveillance” in Xinjiang.[17] A direct consequence of this sanction is that Megvii has lost access to American components critical to its supply chain. In view of the aforementioned bill proposed by Marco Rubio, Megvii may face the prospect of being denied to U.S. capital, too. This is to say nothing of the risk of direct financial sanctions on Megvii by the U.S., possibly pursuant to the Sergei Magnitsky Rule of Law Accountability Act of 2012 (“Global Magnitsky Act”), as proposed by the U.S. Congressional-Executive Commission on China.[18]
Should Megvii be subject to any form of financial sanctions, a listed Ant Group would effectively act as a conduit for Megvii to access U.S. capital - a recipe for secondary financial sanctions on Ant Group itself. Alternatively, the U.S. may impose primary financial sanctions on Ant Group directly, citing its role in “enabling” the alleged human rights abuses by Megvii in Xinjiang. As U.S. Treasury Secretary Steven Mnuchin - who is probably the most China-friendly official in the Trump administration - puts it, “the U.S. is “committed to using the full breadth of its financial powers to hold human rights abusers accountable in Xinjiang and across the world.”[19]
Unfortunately, Ant Group fails to touch on the risks of financial sanctions emanating from its shareholding in Megvii at all. With a grand total of only one reference to Megvii in the prospectus, Ant Group fails to identify the potential for importing sanctions from Megvii into itself. Given the materiality of such sanctions risks, Ant Group must cease all primary sanctioned activities prior to listing, as per Paragraph 3.3 of the Guidance Letter HKEX-GL101-19. However, Ant Group has not divested any holdings of Megvii’s shares to date.
Scenario 3: Ant Group has engaged in secondary sanctionable activity
The issue of Xinjiang will prove to be yet another landmine for Ant Group insofar as its suitability is concerned. On July 31, 2020, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) sanctioned the Xinjiang Production and Construction Corps (“XPCC”) pursuant to the Global Magnitsky Act, citing “serious human rights abuses against ethnic minorities in Xinjiang”.[20] As a result, all transactions by U.S. entities or within (or transiting) the U.S. that involve any property or interests in property of the XPCC are prohibited unless otherwise authorized. In parallel, the U.S. has also imposed financial sanctions on a number of senior Chinese officials, including Xinjiang’s party secretary Chen Quanguo.[21]
According to China’s State Council, the XPCC is a 2.7-million-strong paramilitary organization in Xinjiang, controlling sectors ranging from agriculture to manufacturing and from education to medical care, accounting for 17% of Xinjiang’s GDP.[22] Given the XPCC’s ubiquitous presence in Xinjiang, it will be virtually impossible for Ant Group from disentangle itself from the XPCC’s cobweb of relations in the region entirely, considering Alipay’s own reach of over 1 billion users and 80 million merchants all around China (some of whom could be sanctioned Chinese officials Ant Group would dare not offend). In other words, there is a considerable chance that Ant Group will fall foul of U.S. secondary sanctions under the Global Magnitsky Act.
Notwithstanding the materiality of the Xinjiang factor, any discussion of Xinjiang-related secondary sanctionable activities is conspicuous by its absence in Ant Group’s prospectus. It is questionable whether Ant Group has provided a sound legal analysis of whether its secondary sanctionable activity would likely result in the imposition of any sanctions against itself or any other relevant persons - let alone adopting appropriate measures to deal with the material sanctions risks identified - as per Paragraph 3.4 of the Guidance Letter HKEX-GL101-19.
In view of the foregoing, one can hardly avoid the conclusion that Ant Group has breached Main Board Listing Rule 2.13(2), by purposely omitting material facts of an unfavorable nature and/or failing to accord them with appropriate significance in the prospectus. Generally speaking, Ant Group may have breached HKEX-GL101-19 Paragraph 3.7 for failing to prominently disclose details of the sanctioned and sanctionable activities in the “Summary”, “Risk Factors” and “Business” sections of its prospectus, including:
(i) the nature and size of its sanctioned and sanctionable projects and businesses in China in general, and in Xinjiang in particular;
(ii) whether Ant Group has reasons to believe it will be deemed a sanctioned target; and
(iii) the background of the counterparties (e.g. Megvii, XPCC, and sanctioned Xinjiang officials), the revenue recognized from sanctioned and sanctionable activities, and the current status of such activities.
For the sake of clarity, Ant Group’s problem here is not one of disclosure, but one of suitability. Without adequate disclosure, however, there is no basis on which Ant Group’s suitability can be assessed by the average investor, or the Listing Committee, in respect of a subject matter that can be as political as it is technical. Unfortunately, Ant Group remains in a state of denial. On the same day as Marco Rubio submitted the bill on financial sanctions, Ant Group’s CFO Cyril Xinyi Han went on the offensive, portraying U.S. sanctions as “mere media propaganda, with no foundation of truth at all”.[23] This testifies to the seriousness, or lack thereof, with which Ant Group is prepared to establish its suitability.
(B) Understated materiality of U.S. financial sanctions on Ant Group
In a similar vein, Ant Group also dishes out an intolerably light treatment of the materiality of sanctions risks in the prospectus. The real risk of losing access to the U.S. financial system - and the U.S. dollar, by extension - is sketched out in the most generic sense, with no assessment whatsoever of the potential qualitative and quantitative impact on Ant Group’s business plan. There are two reasons why this is unacceptable:
(i) Unlike other applicants, Ant Group confronts a considerable risk of U.S. financial sanctions in its capacity of a sanctioned target, an agent of primary sanctioned activity, an agent of secondary sanctionable activity, or a combination of the above (Section A); and
(ii) The impact of U.S. financial sanctions on Ant Group is material (Section B, see below).
The very purpose of Ant Group’s Hong Kong listing is global expansion. As the Chinese domestic market is reaching a point of saturation amidst cut-throat competition with Tencent, global expansion is not a matter of nice-to-have, but one of necessity. It is only natural that Ant Group devises a business plan to “continue to seek out opportunities overseas to enable merchants and consumers to conveniently receive and make payments and remit globally.” (p.173) It is noted further that Southeast Asia has become a particular area of focus for Ant Group. For example, Ant Group has invested heavily in the region’s e-payment players ranging from Myanmar’s Wave Money and Thailand’s Ascend Money to Indonesia’s Dana and the Philippines’ Mynt. Ant Group is also understood to have applied for a digital wholesale bank license in Singapore. If authorized, the digital bank will become a stepping stone for Ant group to expand its financial services provision into other Southeast Asian economies.
In other words, Ant Group is critically dependent on the dollar to finance its future-proof global expansion plan. Should Ant Group fall under financial sanctions, U.S. financial institutions would be prohibited from making any transactions with Ant Group at all. This would, by implication, castrate Ant Group’s access to the U.S. dollar, which is ultimately cleared by the U.S. financial system. Completely cut off from the global currency, Ant Group would find it next to impossible to conduct its normal course of business in the 200+ countries and regions with online payment services, let alone embark on overseas expansion in any meaningful sense - all with apocalyptic consequences for Ant Group’s business strategy.
At the risk of stating the obvious, U.S. financial sanctions are global in nature. Ant Group cannot hope to pretend it will be business as usual with non-American business partners, using a currency other than the U.S. dollar. The case of INSTEX is illustrative. As a piece of financial infrastructure for trade between the European Union and Iran, INSTEX has failed to solicit support from major European companies, which remain forever wary of the greater evil of U.S. financial sanctions.
To make things worse, the impact of financial sanctions on Ant Group is not only commercial, but also financial. Under the workings of the Linked Exchange Rate System, the trading of shares listed on the Stock Exchange of Hong Kong is bound to go through the U.S. financial system at some point. Specifically, overseas investors wishing to purchase the shares of Ant Group will have to go through two steps, namely (i) wire U.S dollars from an overseas financial institution to a local one; and (ii) exchange U.S. dollars for Hong Kong dollars. The exact sequence of the process may vary, though the point remains that either part of the process must involve at least one U.S. financial institution as a clearing bank. In the event of financial sanctions, this chain of process will break down. This is the context in which the “de-pegging” proposal favored by the CPDC is really a euphemism for U.S. financial sanctions. As a matter of course, overseas investors will be barred from purchasing the shares of Ant Group. Share prices will crash, to the detriment of both local and overseas investors. On the other hand, Ant Group’s very purpose of getting listed and raising dollars in Hong Kong would be defeated, with its financial position and business operations existentially shaken.
It is thus disturbing that Ant Group does not bother to disclose the materiality of the risks of U.S. financial sanctions with any degree of specificity, contra Main Board Listing Rule 2.13(2). At a minimum, Ant Group should estimate the extent to which it is dependent on dollar financing before and after listing, on the basis of which an impact analysis is to be conducted. Given the significance of the subject matter, Ant Group should publish the results of the impact analysis to the public.
Nor does Ant Group disclose whether it has implemented effective and adequate internal control measures to mitigate this risk as per HKEX-GL101-19 Paragraph 3.6. As far as the guidance note is concerned, Ant Group should also give an undertaking, inter alia, (i) not to directly or indirectly apply the IPO proceeds and any other funds raised through the Stock Exchange of Hong Kong to finance or facilitate any sanctioned and sanctionable activity; and (ii) to terminate before listing all obligations under the relevant contracts that constitute the sanctioned activity and sanctionable activity, and have measures in place to ensure compliance with the undertaking. Absent further disclosure by Ant Group, there remains doubts as to any reasonable person can be assured of Ant Group’s suitability for listing pursuant to Paragraph 8.04 of the Listing Rules.
(C) Understated materiality of U.S. financial sanctions on the Hong Kong Exchanges and Clearing Limited (“HKEX”)
Given both the probability and materiality of financial sanctions on Ant Group, the HKEX should be particularly mindful of the potential legal and reputational costs incurred to itself of approving Ant Group’s listing application, as per Paragraph 3.5 of HKEX-GL101-19. In the event of financial sanctions on Ant Group, moreover, the HKEX would be prohibited from making any contribution or provision of funds, goods, or services by, to, or for the benefit of Ant Group. In other words, the HKEX itself might be subject to secondary sanctions if the U.S. determined that the HKEX was materially complicit in Ant Group’s evasion of the sanctions, either in the course of approving Ant Group’s listing application or acting as a clearing agent for trading of Ant Group’s shares. Depending on the severity of U.S. actions, the HKEX might also incur risks of money laundering by acting as a conduit for Ant Group’s illicit financial activities. It goes without saying that all this would pose existential risks to the HKEX - and indeed the Hong Kong economy as a whole. Thus, the HKEX should reserve every right to reject Ant Group’s listing application.
In reviewing Ant Group’s application, the HKEX Listing Committee is invited to refer to HKEX-GL101-19 Paragraph 3.8. Given this combustible geopolitical environment, it would be very bold of the Listing Committee to dismiss out of hand that Ant Group would not be caught by any of the following criteria, quoted in full below:
“The Exchange is unlikely to approve the listing if (a) any sanctions risks to or sanctions imposed on the applicant materially undermine its ability to continue its operations; (b) an applicant states that the funds are raised to finance Sanctioned Activities; or (c) its listing would cause a significant risk to the Relevant Persons or reputational risk to the Exchange.”
Concluding remarks
While I note that Ant Group may have provided further information on sanctions risks in its private correspondence with the HKEX, I am of the view that such information should be open to the public for scrutiny due to the exceptional nature of this case. In view of both the probability and materiality of financial sanctions on Ant Group, the HKEX should not shrink from fulfilling its frontline regulatory role in protecting investors who may not be aware of grave implications of these sanctions for Ant Group’s financial position and business operations.
In parallel, the Securities and Futures Commission (“SFC”) should intervene. Specifically, the SFC should not hesitate to exercise its statutory power pursuant to the Securities and Futures (Stock Market Listing) Rules (“SMLR”) to object to the listing of Ant Group. It is clear that the SFC has very strong grounds to make such an objection under section 6(2) of SMLR, including that:
(i) The application does not comply with the requirement under section 3(a), as Ant Group fails to comply with the Listing Rules and the Guidance Letter HKEX-GL101-19; and under section 3(c), as Ant Group fails to provide such particulars and information about either the probability or the materiality of U.S. financial sanctions in order to enable an investor to make an informed assessment of its business operations and financial position;
(ii) The application is misleading as to the material risks of financial sanctions, or the omission thereof; and
(iii) It would not be in the interest of the investing public or in the public interest for Ant Group to be listed, in view of both the heightened probability and the grave materiality of U.S. financial sanctions on Ant Group - and the HKEX, by extension - under the current combustible geopolitical climate.
At the very least, the SFC should serve a notice to Ant Group requiring it to supply such further information as the SFC may reasonably require for the performance of its functions under relevant rules and regulations.
To repeat, the fundamental flaw of Ant Group’s listing application is not one of disclosure, but of suitability. But without disclosure, there can be no discussion of suitability. The irony is that Ant Group declares that “the story of Ant is a story of building and cherishing trust” (p.163). When scanning through Ant Group’s listing document, though, it is hard not to generate an impression that Ant Group has been evasive and equivocating over a number of sanctions-related of material nature, to the detriment of investors and indeed the integrity of Hong Kong’s listing regime. The Listing Rules, it appears, have been more honored in the breach than the observance.
In view of the foregoing, I urge you to delay Ant Group’s listing without further ado. As long as Ant Group fails to address all of the material concerns contained in this letter, there can be no basis at all on which we can ascertain whether Ant Group is indeed suitable for listing.
Sincerely yours,
[Name]
[1] “Sanctioned Target” means any person or entity (i) designated on any list of targeted persons or entities issued under the sanctions-related law or regulation of a Relevant Jurisdiction; (ii) that is, or is owned or controlled by, a government of a Sanctioned Country; or (iii) that is the target of sanctions under the law or regulation of a Relevant Jurisdiction because of a relationship of ownership, control, or agency with a person or entity described in (i) or (ii). See HKEX Guidance Letter, “Guidance on Sanctions Risks”, HKEX-GL101-19, March 2019.
[2] “Primary Sanctioned Activity” means any activity in a Sanctioned Country or (i) with; or (ii) directly or indirectly benefiting, or involving the property or interests in property of, a Sanctioned Target by a listing applicant incorporated or located in a Relevant Jurisdiction or which otherwise has a nexus with such jurisdiction with respect to the relevant activity, such that it is subject to the relevant sanctions law or regulation. See HKEX Guidance Letter, “Guidance on Sanctions Risks”, HKEX-GL101-19, March 2019.
[3] “Secondary Sanctionable Activity” means certain activity by a listing applicant that may result in the imposition of sanctions against the Relevant Person(s) by a Relevant Jurisdiction (including designation as a Sanctioned Target or the imposition of penalties), even though the listing applicant is not incorporated or located in that Relevant Jurisdiction and does not otherwise have any nexus with that Relevant Jurisdiction. See HKEX Guidance Letter, “Guidance on Sanctions Risks”, HKEX-GL101-19, March 2019.
[4] White House, “Executive Order on Addressing the Threat Posed by TikTok”, August 6, 2020. https://www.whitehouse.gov/presidential-actions/executive-order-addressing-threat-posed-tiktok/
[5] White House, “Executive Order on Addressing the Threat Posed by WeChat”, August 6, 2020. https://www.whitehouse.gov/presidential-actions/executive-order-addressing-threat-posed-wechat/
[6] Bloomberg, “Trump Widens China Tech Attack, Ordering Bans on TikTok and WeChat”, August 7, 2020. https://www.bloomberg.com/news/articles/2020-08-07/trump-signs-tiktok-ban-as-u-s-boosts-pressure-for-sale-of-app
[7] U.S. Department of the Treasury, “International Emergency Economic Powers Act”. https://home.treasury.gov/system/files/126/ieepa.pdf
[8] Reuters, “Trump says looking at pressuring other Chinese companies after Bytedance,” August 16, 2020. https://www.reuters.com/article/us-usa-trump-alibaba-idUSKCN25B11B
[9] U.S. Department of Commerce, “Commerce Department Prohibits WeChat and TikTok Transactions to Protect the National Security of the United States”, September 18, 2020. https://www.commerce.gov/news/press-releases/2020/09/commerce-department-prohibits-wechat-and-tiktok-transactions-protect
[10] ibid.
[11] RWR Advisory Group, “Risk Profile: Ant Technology Group”, September 6, 2020. RWR Advisory Group, Risk Profile: Ant Technology Group, Sep 6, 2020.
https://www.rwradvisory.com/wp-content/uploads/2020/09/RWR-Ant-Risk-Profile-Report-9-6-2020.pdf
[12] Committee on Present Danger: China, “CPDC Letter to POTUS on the Ant I.P.O”, September 14, 2020. https://presentdangerchina.org/wp-content/uploads/2020/09/CPDC-Letter-to-POTUS-on-the-Ant-IPO-91420.pdf
[13] Committee on Present Danger: China, “CPDC Letter to Hong Kong Exchanges and Clearance, Ltd. concerning the Ant Technology Group I.P.O.”, September 14, 2020. https://presentdangerchina.org/wp-content/uploads/2020/09/CPDC-Letter-to-the-HKEX-Leadership-91420.pdf
[14] Reuters, “Rubio unveils bill to kick blacklisted Chinese firms out of U.S. markets”, October 27, 2020. https://www.reuters.com/article/us-usa-china-markets-idUSKBN27C25B
[15] Reuters, “U.S. should try to delay IPO of China’s Ant Group, Senator Rubio says”, October 10, 2020.
https://www.reuters.com/article/usa-antfinancial-ipo-idUSKBN26V03U
[16] Reuters, “Exclusive: Trump administration to consider adding China’s Ant Group to trade blacklist - sources”, October 15, 2020. https://in.reuters.com/article/uk-usa-antfinancial-blacklist-exclusive/exclusive-trump-administration-to-consider-adding-chinas-ant-group-to-trade-blacklist-sources-idINKBN26Z2UV
[19] U.S. Department of the Treasury, “Treasury Sanctions Chinese Entity and Officials Pursuant to Global Magnitsky Human Rights Accountability Act”, July 9, 2020. https://home.treasury.gov/news/press-releases/sm1055
[20] U.S. Department of the Treasury, “Treasury Sanctions Chinese Entity and Officials Pursuant to Global Magnitsky Human Rights Executive Order”, July 31, 2020. https://home.treasury.gov/news/press-releases/sm1073
[21] U.S. Department of the Treasury, “Treasury Sanctions Chinese Entity and Officials Pursuant to Global Magnitsky Human Rights Accountability Act”, July 9, 2020. https://home.treasury.gov/news/press-releases/sm1055
[22] The State Council Information Office of the People’s Republic of China, “White Paper on History and Development of the Xinjiang Production and Construction Corps”, October 5, 2014. http://www.scio.gov.cn/zfbps/ndhf/2014/Document/1382598/1382598_1.htm
[23] HKEJ, “制裁非事實 無礙全球化”, October 27, 2020. https://www1.hkej.com/dailynews/article/id/2616241/