U.S. Sanctions Targeting Chinese Military Companies: Practical Considerations for Asian Compliance Officers

In June 2020, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) tightened restrictions on certain military exports by expanding the list of items covered by licensing and broadening the definition of “military end use (MEU)” to cover wider categories of activity. The new rule imposes new restrictions on exports to military end users in China.

This was then followed by several sanctions measures targeting specific entities owned, controlled by or associated with the Chinese military, including the November 2020 Executive Order that will prohibit US persons from purchasing securities of “Communist Chinese military companies.”

Duration: 75 minutes

Speakers: Sally Peng , Managing Director, FTI Consulting Export Controls and Sanctions | Erica Ip , Senior Director, FTI Consulting Export Controls and Sanctions

Moderator: Saskia Rietbroek CSS, Executive Director, ACSS

Date: Thursday, Dec 17, 2020

Time: 3 PM – 4:15 PM SHANGHAI TIME

This webinar will discuss:

  • New definition of military end-use and end-user (MEU)
  • Latest US sanctions on Chinese military and related entities
  • How can Asian companies and financial institutions cope with these changes by identifying and addressing relevant risks

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Sally Peng

Managing Director

Forensic & Litigation Consulting

Sally Peng is a Managing Director in the Export Controls & Sanctions practice at FTI Consulting and is based in Hong Kong. She is an expert in export controls and economic sanctions, international trade strategy, and global supply chain optimisation and compliance.

Sally has extensive experience advising public-listed companies on their complex encryption programmes under US and Hong Kong laws and in other Asia Pacific jurisdictions, including representing her clients in front of relevant government agencies in those jurisdictions. She also advises several China-based clients regarding US sanctions regulations and has preformed on-site impact analysis. In addition, she works closely with her clients’ legal, procurement and logistics teams to build best-in-class Export Control and Sanction compliance programmes. Her industry coverage includes banks, telecommunications, national defense contractors, heavy machinery, and research universities.

Sally has been a trusted advisor for many MNCs on their international trade and customs issues. She served as team leader for several global retailers in large-scale customs duty-saving projects in over ten Asian countries. She also assisted multiple Asia-based companies in defending antidumping and countervailing cases with US Department of Commerce and US Customs and Border Protection (CBP). During the on-going US-China trade war, Sally is sought after by her clients to advise them on mitigating strategies against US section 301 and 232 retaliation tariffs, free trade agreements, trade preference programmes and country of origin issues. Her industry coverage includes apparel, footwear, handbag & leather goods, hardline goods and consumer electronics.

Sally takes her passion for international trade beyond individual companies, having participated in negotiations of the Trans-Pacific Partnership (TPP) and Regional Comprehensive Economic Partnership (RCEP), as well as serving as a key member on numerous trade missions, including to China, Vietnam, Indonesia, Cambodia, Bangladesh, and various African countries. She is also highly involved in the American Chamber of Commerce in Hong Kong, serving on several committees, including as Co-Chair of the Apparel, Footwear & Supply Chain Committee. She is also a Senior Advisor to the Hong Kong General Chamber of Textiles Limited.

Prior to FTI Consulting, Sally was based in Beijing & Hong Kong for over ten years and served as the Asia Pacific practice leader of a US-based law firm focused on International Trade and Customs.

Sally holds a J.D. from the University of Florida Levin College of Law, a Diploma from Peking University Law School in Beijing, and a B.A. from National Chengchi University College of Law. She is a native Mandarin speaker and is fluent in English.

Erica Ip

Senior Director

Forensic & Litigation Consulting

Erica is a Senior Director in the Export Controls & Sanctions practice at FTI Consulting, and she is based in Hong Kong. Erica specialises in regulatory compliance including export controls, sanctions, anti-money laundering, and anti-bribery & anti-corruption.

Erica has worked with companies in many industries, especially telecommunication, financial institutions, pharmaceutical, energy and consumer goods. Erica helps her clients to understand potential compliance risks they are exposed to by conducting risk assessments and audits, in particular transaction testing, gap analysis, document review and interview. She also advises her clients on risk management and delivering compliance programme implementation and enhancement, to mitigate and control risks through system optimization, policies and procedures uplift, and training.

Erica specialises in data analysis and visualization and she has extensive experience in presenting observations and findings to client’s management, external counsel and regulators. Erica assisted a client (that is under U.S. Government monitorship) in building a best-in-class compliance programme and also assisted preparing responses to document production requests, in order to meet their obligations according to two settlement agreements with U.S. regulators. Erica led and managed multiple work streams simultaneously, with the teams executing ground work across China and Hong Kong. Together the team assessed and enhanced the existing compliance programme for over 100 subsidiaries which the client has.

Erica also acts as an independent forensic investigator on behalf of special committee, shareholders, regulators and management regarding allegations of fraud, misconduct and violation by employees or companies.

Prior to FTI Consulting, Erica has worked for over 7.5 years in a Big 4 forensic practice. Erica is an active member of the Association of Chartered Certified Accountants and holds a B.Sc. in Accounting and Finance from University of Warwick and a LL.M. from University of London in the UK. Erica is fluent in Cantonese, Mandarin and English.