Regulatory intelligence for US exporters

Biden, Trump Diverged on Sanctions, Export Controls, Report Says

While the Biden and Trump administrations both frequently imposed financial sanctions and export controls on China, the Biden administration has made greater use of two key tools: the Treasury Department’s Specially Designated Nationals and Blocked Persons List and the Commerce Department’s Entity List. That's according to a new report by the Center for a New American Security (CNAS).

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The Trump administration added 216 Chinese individuals and entities to the SDN List, which is “the United States’ most stringent financial sanction,” and added 259 Chinese individuals and entities to the export-restricting Entity List, the report says. The Biden administration has exceeded both numbers amid increased geopolitical tension. As of Aug. 30, it had added 432 individuals and entities to the SDN List and 412 individuals and entities to the Entity List.

The Biden and Trump administrations applied these tools somewhat differently, CNAS said. The Trump administration mainly used SDN designations against China to reinforce sanctions against Iran and North Korea and address rising concerns about the plight of China's Uyghur minority and the state of democracy in Hong Kong. While the Biden administration has kept countering China-Iran cooperation as a priority, many of its SDN designations have been aimed at China’s connections to Russia following Russia’s 2022 invasion of Ukraine.

Although both administrations mainly used the Entity List to respond to China’s military modernization, they prioritized different areas. The Trump administration focused on entities that support China’s missile, nuclear weapons and unmanned aerial vehicle programs and contribute to the country’s semiconductor and supercomputing capabilities. The Biden administration has concentrated on limiting China’s access to dual-use technology, such as biotechnology, quantum computing and semiconductors.

While the findings suggest that the U.S. will likely continue using financial sanctions and export controls against China regardless of who wins the Nov. 5 presidential election, a second Trump administration and a Harris administration could take "substantially" different approaches to applying these tools, the report says. A major geopolitical event could also “play an important role in shifting sanctions strategy, as was evident with Russia during the Biden administration,” CNAS wrote.