On July 1, the U.S. Departments of State, Commerce, Homeland Security, and Treasury issued an advisory on the risks for businesses with potential exposure in their supply chain to entities engaged in human rights abuses in the Xinjiang Uyghur Autonomous Region (Xinjiang).

Is anyone making any system/procedural changes to look for any related suspicious activity based on this advisory? A consideration would be to add a keyword search to alert for activity involving Xinjiang, but not sure if that would be sufficient or just a waste of time. I have read the background documentation, but am at a loss as to what we should be doing. Any input out there? Thank you.

We added Xinjiang as a keyword and alerted our wire/ACH teams as well.

Thank you. That confirms what we were thinking, I wanted to make sure we were not missing something.

I appreciate your help.

How are you going to deal with a positive match?

If you have a plan what about these companies who have bee implicated?

https://www.business-humanrights.or...oss-provinces-includes-company-responses

PS: It is a good idea to alert for this region but there are many companies that are not engaged in this behavior and as someone who spent a lot of time with Chinese export (Trade Finance) some are extremely difficult to research. .

You should first evaluate your sanctions screening lists already in place for any transactions with a nexus to international business activities. For most places, that's strictly wires and IATs, but for some letters of credit and other products/services may come into play.

If you're already screening the BIS' Entity List or the "Consolidated List" (retrieved from the International Trade Administration), which many Institutions and correspondent Banks are in my experience, then you'll be pretty well covered because BIS is adding the specific entities of concern to their list. And with the most recent advisory, it would not be surprising to see this action escalate to sanctions against those specific entities (OFAC has indicated they'll do so under the Magnitsky Act instead of a separate program).