Morrison & Foerster partner Chen Zhu was quoted in an article “China walks a trade tightrope between Russia and the West”, published by Marketplace on March 17, 2022.
According to Chen, if a Russian company and a Chinese company are doing business in U.S. dollars, and the payments flow through a U.S. bank, that is an issue that falls under primary sanctions.
Chinese firms could still be subject to secondary sanctions if a transaction is settled in Chinese yuan, uses a Chinese bank and China’s Cross-Border Interbank Payment System. “America can say, ‘Yes, these dealings are outside of my control, but since you are dealing with a target of my sanctions, I’m going to impose sanctions on you as well,’” Chen said.
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