WRITTEN EVIDENCE SUBMITTED BY HONG KONG WATCH

(TRUK0125)

Recommendations

1. Implement the Foreign Influence Registration Scheme (FIRS) as scheduled, and include entities from the People’s Republic of China (PRC) and Hong Kong on the Enhanced Tier of FIRS.

On 16 December 2024, Security Minister Dan Jarvis MP named the PRC as one of the three leading states – along with Russia and Iran – that pose an ongoing threat to British security.[1] That is why the Foreign Influence Registration Scheme (FIRS) should be introduced without further delay, and the PRC should be placed alongside these two other states in the Enhanced Tier of FIRS.

2. Introduce visa restrictions on employees of state organs involved in transnational repression, including the PRC’s United Front Work Department and proxies such as the Overseas Chinese Affairs Office.

Following the example of Canada, the UK government should introduce visa restrictions on current employees of specific foreign state entities involved in transnational repression, surveillance and espionage, or at the minimum introduce a requirement that all employees of specific foreign state entities are required to register under FIRS.

3. Introduce amendments via the forthcoming Cyber Security and Resilience Bill and the Online Safety Act 2023 to criminalise digital transnational repression, including state-directed digital transnational repression.

Hostile cyber actors, including the PRC, are increasingly targeting the UK’s critical sectors and supply chains. In some cases these attacks can be linked to transnational repression activities. In light of the increased threat from hostile states and state-sponsored actors, the forthcoming Cyber Security and Resilience Bill should incorporate language to specifically address cyberattacks on individuals targeted by hostile states.

The Online Safety Act 2023 should also be amended to include state-directed online harassment and other harmful cyber activities against targeted individuals under the Foreign Interference Offence.

4. Revise the ‘state threats aggravating factor’ of the National Security Act 2023 to include criminal activity intended to benefit a foreign power.

Many acts of transnational repression are not covered by the existing language of the National Security Act 2023. The requirements of the ‘state threats aggravating factor’ should be updated to apply to criminal acts – such as harassment, stalking, threats, or physical violence – against targeted individuals, where such activity is undertaken in support of, or for the benefit of, a foreign state. This would reflect the attempt by foreign states to encourage individuals to commit harm on targeted activists without express direction from the state to that individual.

5. Create institutional links between the UK constabulary and British National (Overseas) communities in the UK

The UK government should create institutional links between UK constabulary forces and British National Overseas (BNO) Hong Konger communities, to ensure that incidents of transnational repression are logged and appropriate follow-up actions are taken where necessary.

This could take the form of a reporting hotline for BNO Hong Kongers and other at-risk groups to file reports of possible transnational repression incidents, and semi-regular check-ins with high-risk individuals such as bountied activists. 

This could also take the form of a designated community lead within each regional police force, with responsibility for overseeing community engagement work. This community engagement work could involve establishing a presence at BNO Hong Konger community events, such as Lunar New Year fairs, to encourage BNO Hong Kongers to interact with UK police and report potential incidents.

Impact of transnational repression

3. Which states are currently understood to be the biggest perpetrators of transnational repression in the UK? What are the main methods employed by such actors in the UK?

1. According to Freedom House, the PRC “conducts the most sophisticated, global, and comprehensive campaign of transnational repression in the world.”[2] A technologically advanced and economically dominant global power, with a sophisticated bureaucracy trained in Leninist techniques of internal party discipline – such as surveillance, anti-corruption investigations, and intimidation through criticism[3] – the PRC is uniquely placed to conduct transnational repression (TNR) activities across the globe.

2. Compared to some other authoritarian states, which coordinate acts of TNR through extralegal means or as an extension of espionage activities, the PRC is noteworthy for the extent to which it institutionalises and codifies TNR through legislation. While violence, harassment, and surveillance are all used by the PRC to intimidate individuals in the UK, the PRC is less inclined towards high-profile acts of explicitly state-directed violence, such as the extrajudicial killing of dissidents.

3. Instead, the PRC exerts repressive influence through subtler methods, leveraging international policing bodies such as INTERPOL, criminalising international advocacy through national security legislation with extraterritorial application, and signalling support for violence against overseas activists and human rights defenders via official statements and diplomatic channels.

4. The PRC’s TNR activity is mostly targeted at members of minority ethnic, religious, and political identity groups whose existence is deemed a potential risk to national security. We will focus on TNR aimed at overseas Hong Kongers, which falls within the ambit of our advocacy work.

5. Much of the PRC government’s TNR activity is coordinated by, and implemented through, the government of the Hong Kong Special Autonomous Region (HKSAR). The HKSAR government is a devolved regional authority under the state sovereignty of, and answerable to the government of the PRC, but it deserves to be highlighted as a separate entity due to Hong Kong’s distinct political and legal structures, and the prevalence of Hong Kong residents in the UK.

6. Since 2020, the PRC has, in conjunction with supportive HKSAR politicians, taken a number of steps to undermine the “high level of autonomy” in legal and political matters afforded to Hong Kong by the Basic Law, Hong Kong’s mini-constitution, and the 1984 Sino-British Joint Declaration.[4] As a consequence, the Hong Kong government has become increasingly aligned with the PRC government, and has accrued additional legal powers with which to pursue activists and conduct TNR across the globe.

7. On 30 June 2020, in contravention of Articles 14 and 18 inter alia of the Basic Law, the National Party Congress of the PRC imposed the Hong Kong National Security Law (HKNSL) on the HKSAR. The HKNSL broadly defines and criminalises secession, subversion, terrorist activities, and collusion with a foreign country or with external elements to endanger national security. The maximum penalty under the law is life imprisonment.[5]

8. On 23 March 2024, the Hong Kong government – following ‘patriotic’ reforms to ensure only pro-Beijing politicians could run for office[6] – passed the Safeguarding National Security Ordinance (SNSO) into law, less than two months after the initial consultation document for the legislation was published.[7] The law broadly defines and criminalises five types of offenses, including treason, espionage, and theft of state secrets. The maximum penalty under the law is also life imprisonment.

9. These two laws, together with ancillary acts of legislation and the aforementioned ‘patriotic’ reforms to Hong Kong’s electoral system, have fundamentally curtailed the exercise of civil and political rights in Hong Kong as guaranteed under the International Covenant on Civil and Political Rights (ICCPR), to which the HKSAR is a signatory.[8] They have also equipped the Hong Kong government with legal tools readily adaptable for conducting TNR.

10. Indeed, it is arguable that conducting TNR is the main purpose of introducing the SNSO. The SNSO is quite clearly intended to intimidate and, where possible, prosecute Hong Kong activists, journalists, and former legislators, as well as foreign non-profit organisations (NGOs) sympathetic to or supportive of the pro-democracy movement and human rights more generally within Hong Kong.

11. The most powerful tool of TNR within both the HKNSL and the SNSO is the extraterritoriality clause, found within Article 38 of the HKNSL and attached to each category of offense within the SNSO. The HKNSL’s extraterritoriality clause states:

“This Law shall apply to offences under this Law committed against the Hong Kong Special Administrative Region from outside the Region by a person who is not a permanent resident of the Region.”[9]

12. It is fairly evident that much of the SNSO is specifically targeted towards overseas activists, referred to as ‘absconders’ within the text of the law. The SNSO gives the Hong Kong government powers to revoke HKSAR passports, cancel professional qualifications, and withdraw social benefits in targeting activists overseas, further increasing the cost of dissent.

13. The offences included within the SNSO, with extraterritoriality clauses attached, are also clearly targeted towards overseas activists. New offences introduced by the SNSO include ‘Participating in or supporting external intelligence organisations or receiving advantages from external intelligence organisations’ and ‘External interference’, both of which are expansively defined to potentially include a range of normal advocacy activities by NGOs and activists.

14. The HKNSL and SNSO also equip the Hong Kong government with the ability to conduct TNR in the digital sphere. Article 43 of the HKNSL gives police the ability to demand the removal of any online or offline content deemed in violation of the HKNSL, and grants extensive powers for interception of communications and search of premises.[10] Clause 48 of the SNSO creates the offence of ‘Endangering national security through a computer or an electronic system’, which can be used to ban or criminalise certain websites or social media that allegedly endanger national security, regardless of the nationality of the creators or a site’s web domain.[11]

15. In this section, we have recited the relevant clauses of the HKNSL and SNSO at length because they illustrate a crucial dimension of TNR as practiced by the PRC and HKSAR governments. This form of TNR is highly institutionalised and codified, given a gloss of legality and legitimacy via use of Hong Kong’s legislative bodies and judiciary. It is reflective of the PRC’s greater state capacity, its relative disinclination to be perceived as a lawless actor on the world stage,[12] and its desire to conduct ‘public opinion work’ on mass populations,[13] not merely shock critics and dissidents into silence via one-off acts of brutality. It could be summarised as the desire above all to induce a ‘chilling effect’ among overseas activists and human rights advocates.

16. However, the PRC and Hong Kong governments have also proved willing to indulge in more typical, clandestine methods of transnational repression, such as the surveillance and harassment of prominent activists, directly or indirectly encouraging physical and digital threats of violence, including of a sexual nature, and cyberattacks on individuals or organisations. Incidents of these types are included in the following section.

2. How does transnational repression impact (a) those targeted and (b) their wider communities?

17. Following the 2019 pro-democracy protest movement in Hong Kong, the imposition of the 2020 Hong Kong National Security Law, and the creation of the British National (Overseas) (BNO) visa scheme by the UK government in response to the declining human rights situation in Hong Kong, over 160,000 Hong Kongers have moved to the UK since January 2021,[14] with roughly 285,000 Hong Kongers in total now living in the UK.[15]

18. This large-scale migration includes a number of prominent Hong Kong activists and former legislators, such as Finn Lau, Simon Cheng, Carmen Lau, and Christopher Mung Siu-Tat. The UK also has a number of politicians, journalists and human rights advocates with professional or personal ties to Hong Kong, many of whom are actively engaged in advocacy on Hong Kong.

19. The PRC and Hong Kong governments have responded by criminalising, via the HKNSL and SNSO, the advocacy efforts of these individuals, regardless of nationality or the physical location of those involved.

20. In March 2022, Hong Kong Watch received communications from the Hong Kong Police Force (HKPF) and National Security Bureau, alleging that the Hong Kong Watch website violated the HKNSL and demanding that it be taken down within 72 hours. Failure to comply could result in Hong Kong Watch’s Chief Executive and British citizen Benedict Rogers facing a fine of HK$100,000 (£10,180) and a prison term of up to three years, or potentially life imprisonment.

21. In July and December 2023, the Hong Kong National Security Police issued arrest warrants with HK$1 million (£102,700) bounties for a total of six exiled Hong Kongers who now live and advocate for Hong Kong democracy in the UK: Simon Cheng, Finn Lau, Christopher Mung Siu-Tat, Nathan Law, Johnny Fok and Tony Choi. Arrest warrants with bounties were also issued for a total of five exiled Hong Kong pro-democracy activists who now live in the US, and 2 who now live in Australia.

22. In December 2024, the Hong Kong government announced six more arrest warrants with HK$1 million bounties for exiled Hong Kongers in the UK and Canada, including  Carmen Lau, Chloe Cheung, Tony Chung, Chung Kim-wah, Victor Ho Leung-mau and Joe Tay.[16]

23. In all cases, the announcement of the arrest warrants was followed by instances of the Hong Kong National Security Police questioning the family members of the Hong Kongers who have been issued arrest warrants who continue to live in Hong Kong. This includes the family members of UK-based activists Simon Cheng, Christopher Mung Siu-tat, Nathan Law, and Carmen Lau.

24. The persecution of family members in the PRC or Hong Kong, in order to increase pressure on ‘fugitives’ to return and face prosecution, is a common tactic employed by both the Chinese Communist Party (CCP) and the HKPF. In one instance, a 64-year-old woman living in Melbourne named Zhou Shuqin was compelled to return to the PRC to face charges of embezzlement after her picture and INTERPOL red notice were emblazoned across Chinese state media outlets, and her younger sister's assets were frozen.[17] Uyghur Muslims from the PRC’s Xinjiang region have similarly complained of their families being used as ‘hostages’ to compel them to return to the PRC.[18]

25. The police harassment of family members back home makes many Hong Kongers in the UK anxious about participating in public life. Many remain anxious about being photographed or filmed, as they fear repercussions against family members should they be identified.[19] 

26. Harassment and cyberattacks are also used to intimidate individuals. In 2022, married artist couple Lumli and Lumlong had their social media accounts on Facebook and Instagram banned after being reported for hate posts, shortly after hosting an art exhibition in the Lewisham London Borough, where the contents were critical of the CCP. The couple also received an anonymous message on their phone outlining the route they had travelled in the previous two hours on their way home from a protest in London. In addition, they found they no longer had access to one of their email accounts.[20]

27. In September 2024 The Chaser, a news website run by Hong Kong journalists in the UK, was informed by Google that its company email was being targeted by government-backed attacks. These could include attempts to steal passwords or personal information through emails containing harmful attachments, harmful software download links or links to fake websites.[21]

28. Alongside digital harassment, filming and taking photographs of Hong Kongers, PRC sympathisers have incited physical violence against Hong Kong demonstrators and activists. In June 2023, Hong Kong demonstrators were violently attacked by a group of Chinese activists in Southampton. Footage taken of the incident showed a group of three men attacking a man and a woman on the street, shouting in Mandarin: ‘Hong Kong belongs to China.’

29. The most serious incident of violence occurred in October 2022, when BNO visa holder Bob Chan was beaten by masked men on embassy grounds while peacefully protesting against Chinese leader Xi Jinping at the Chinese Consulate in Manchester.[22] The Chinese Consul General along with a number of embassy staff also assaulted other Hong Kong protestors, pulling the hair and shoving fingers into the eyes of protestors. In an interview the Consul General confirmed his participation in the assault and stated that it was “his duty” to attack the protestors.[23]

30. PRC officials often respond to such incidents by defending the instigators. In response to the attack in Manchester, the Chinese embassy issued a statement warning that ‘[p]roviding shelter to the Hong Kong independent elements will only, in the end, bring disaster to Britain.’[24] When CCTV journalist Kong Linlin slapped a volunteer at a Conservative Party conference event organised by Hong Kong Watch in 2018, the Chinese embassy defended her actions, stating that it was ‘completely unacceptable’ for her to be removed from the event.[25]

31. Most seriously, there are concerns that the PRC and Hong Kong governments, in addition to intimidating activists and tacitly encouraging violence against them, have moved into actively conducting clandestine surveillance and harassment operations against targeted individuals.

32. Public figures and parliamentarians in several countries have raised concerns around the 14 Hong Kong Economic and Trade Offices (HKETO) which serve as de facto secondary diplomatic missions for the PRC and have been implicated in surveillance of overseas dissidents.

33. In May 2024 in the UK, the Metropolitan Police arrested three men on national security charges related to surveillance of exiled dissidents, one of whom served as Administrative Manager of the HKETO in London. While the court case is ongoing, news of the arrests provoked a wave of concern among Hong Kong communities in the UK.

34. Similar concerns have been raised around Hong Kong Trade Development Councils, from which an employee in Frankfurt, Germany was under investigation for alleged espionage for the PRC in April 2024.

The UK government’s legislative response

4. What steps has the Government taken to address transnational repression in the UK?  What departments have been involved in these steps? How effective is coordination between departments?

35. The UK government’s policy response to TNR, such as it is, has largely been integrated into national security policy, rather than the protection of individual rights. However, progress has been limited and, following the General Election on 4 July 2024 and the subsequent change in administration, the future policy direction of the UK government on TNR is unclear.

36. Relevant existing policy documents include the Integrated Review Refresh 2023, which updated the Integrated Review 2021, Global Britain in a Competitive Age.[26] Following the General Election, Prime Minister Sir Keir Starmer launched the Strategic Defence Review[27] and announced plans to conduct an ‘audit’ of UK-China relations,[28] though neither of these documents have been published to date.

37. The Integrated Review Refresh 2023 included language on the CCP which could feasibly incorporate TNR within its ambit, referring to the need to strengthen the UK’s ‘domestic resilience…partly in response to the epoch-defining and systemic challenge posed by China under the Chinese Communist Party (CCP) [...including] a new focus on tackling state threats to the UK’s democracy, economy and society’.[29] However, repression, including TNR, was not explicitly mentioned as a policy issue.

38. The previous Conservative government established the Defending Democracy Taskforce (DDT) in 2022, which acknowledged the issue of TNR within its remit, but the level of activity of the DDT following the change in administration remains unclear. In the last Parliament the National Security Strategy (Joint Committee) (JCNSS) was supposed to review the work of the Defending Democracy Taskforce, but TNR was not explicitly included in the inquiry’s framework.

39. Policy teams within the Home Office, the Foreign, Commonwealth and Development Office, and the Ministry for Housing, Communities and Local Government all participate within internal governmental policymaking on TNR. However, lack of public communication on activities or strategy regarding TNR means it is difficult to assess what work has been done, or its effectiveness.

6. To what extent has entry into force of the National Security Act 2023, in particular the new offence of foreign interference and the Foreign Influence Registration scheme, helped to strengthen the UK’s ability to tackle transnational repression?

40. With the introduction of FIRS and foreign interference offences under the National Security Act 2023, the UK has taken steps to tackle foreign influence, in cases where such activity is contrary to the interests of the UK. However, intimidation has received less attention in the new framework.

41. Taking effective action against intimidation on behalf of a foreign power is undoubtedly a complex task, and not all potentially threatening behaviour rises to the level of criminal offence. However, as noted above, pro-CCP elements within the UK have already used violence against Hong Kongers. These incidents, while thankfully quite rare, do involve a level of harassment and bodily assault which could constitute grounds for prosecution.

42. The National Security Act 2023 already includes measures to ensure that hostile or aggressive behaviour, such as harassment or assault, can be judged on national security grounds. The Act includes a ‘state threats aggravating factor’ to cover offences not in the Act, but that nevertheless are conducted for or on behalf of foreign states.[30]

43. The foreign power condition can be met in two scenarios:

1. Activity carried out for or on behalf of a foreign power – this includes a wide range of different types of relationship with the foreign state including activity at their request, direction, with their assistance, and with their agreement.

2. Activity carried out with the intention to benefit a foreign power – this includes cases where a person’s primary motivation is, for example, financial but a person also intends, or acts in virtually certain knowledge, that the foreign power will benefit.

It is unlikely that attacks on Hong Kongers would ever meet the first criterion of being ‘for or on behalf of’ the PRC. The CCP does not need to direct sympathetic individuals to attack Hong Kong demonstrators or activists; it creates a discursive environment through propaganda outreach in which such activists are demonised and attacks on them are praised as ‘patriotic.’

44. It is also questionable whether the attacks would meet the second criterion of ‘intention to benefit a foreign power.’ Should an individual sympathetic to a foreign power assault an activist critical of that power, the benefit is primarily negative, the impact measured in what activists choose not to say or do, out of fear of reprisal. It would be difficult to prove the concrete ‘benefit’ to a foreign state, even where a person’s intention was to benefit the state by intimidating its critics.

45. Consequently, it appears that assault would fall under the ‘state threats aggravating factor’ only where a foreign power has expressly requested or directed for an individual to commit violence.

46. Supporting the PRC or CCP is not a crime and Hong Kong Watch supports the right of individuals to express this political opinion. However, assaulting, harassing, blackmailing or otherwise intimidating critics of the PRC or HKSAR is unacceptable and, furthermore, should be contextualised against ongoing attempts by those governments to silence their critics overseas.

47. Where such intimidation occurs against individuals who have been identified by a foreign power – whether through the placing of bounties, the issuance of criminal charges, or the naming of the individual in court cases or official communications – there should be provisions in place to ensure that such intimidation is properly classified as a ‘state threats aggravating factor’ on top of the ordinary criminal offences.

7. How effective is other UK domestic legislation in preventing instances of transnational repression? What gaps have been identified and how may they be addressed?

48. Together with the National Security Act 2023, other relevant legislation in this policy sphere includes the Online Safety Act 2023,[31] the National Security and Investment Act 2021,[32] and the Communications Act 2003.[33]

49. Together, the aforementioned Acts do manage to capture some TNR activities, such as online harassment, threats or acts of physical violence, state-directed espionage, etc. However, in none of these Acts is TNR a priority focus, meaning that some TNR activities are able to fall through the cracks where the scope and definition of existing legislation does not fit neatly together.

50. The Online Safety Act 2023 aims to protect users from harmful online content, including cyberattacks, by placing legal responsibility on tech companies to actively remove illegal content like hate speech, child sexual abuse material, and other harmful content from their platforms; it also requires companies to take steps to prevent cyberattacks via their platforms and software.

51. Although TNR is not a focus of the Act, it does cover online harms caused by state actors within its ambit, through the Foreign Interference Offence. This priority offence requires the removal of illegal, state-sponsored disinformation, forcing companies to take action against a range of state-sponsored disinformation and state-linked interference online. As per our recommendation, the Online Safety Act 2023 should also be amended to include state-directed online harassment and other harmful cyber activities against targeted individuals under the Foreign Interference Offence.

52. In addition and as previously stated, the ‘state threats aggravating factor’ of the National Security Act 2023 should be updated to apply to criminal acts – such as harassment, stalking, threats, or physical violence – against targeted individuals, where such activity is undertaken in support of, or for the benefit of, a foreign state. This would reflect the attempt by foreign states to encourage individuals to commit harm on targeted activists without express direction from the state to that individual.

Diplomatic Relations

13. How is the UK working with other democracies to tackle transnational repression? How can it do better?

53. We encourage the UK government to build on existing multilateral engagement with allies, particularly Five Eyes partners, on constructing a robust and cross-jurisdictional defence against TNR. This cross-jurisdictional work could take the following steps:

-          Establishing a standardised, legal definition of TNR, rather than relying on internal departmental definitions.

-          Empowering relevant governments to implement property- and visa-blocking sanctions on foreign individuals and entities engaging in transnational repression.

-          Developing a national strategy, subject to periodical review, focused on raising costs for perpetrators of TNR and protecting targeted groups.

-          Ensuring relevant employees and law enforcement are equipped to recognize and respond to transnational repression, and directing intelligence agencies to prioritize identifying perpetrators within relevant jurisdictions.

54. In June 2024 the Canadian parliament passed Bill C-70, An Act respecting countering foreign interference. The Bill amends the Canadian Security Intelligence Act (CSIA) and other relevant legislation to provide greater oversight and accountability within existing structures intended to combat foreign interference, including TNR against Canada’s large Hong Kong community. The UK government should mirror the passage of this bill to increase oversight of TNR against the Hong Kong and other diasporic communities in the UK.

55. The UK National Security Act 2023 does not take proactive measures against agents of the Chinese state who, by dint of their employment, are tasked with espionage, interference, and influence operations. Given that the PRC is in permanent violation of its commitments under the Sino-British Joint Declaration and the UK has offered safe harbour to over 160,000 Hong Kongers as a direct result, the JCHR should consider whether further actions should be taken against PRC citizens who are known to be employed by the United Front Work Department or its aliases (such as the Overseas Chinese Affairs Office or OCAO).

56. A precedent for such action was taken by Canada in 2022. The permanent residency application of a former employee of the OCAO was rejected on the grounds that members of organisations that engage in espionage and harm Canada’s interests are barred from migrating to Canada. The ruling was subsequently upheld in judicial review in the Federal Court of Canada.

14. How is the UK’s response to transnational repression affected by its diplomatic relationships with perpetrator states and how does transnational repression factor into the UK’s diplomatic decision-making?

57. Under previous administrations, the UK government has condemned the PRC government for cyberattacks[34] and espionage,[35] incidents which fall under the broad ambit of national security  policy, although incidents of violence such as at the Manchester consulate in October 2022 received a comparatively muted response.[36]

58. Under the current administration, the UK government’s strategy with regard to the PRC is to ‘strengthen dialogue’ while ‘avoiding surprises’ and engaging ‘honestly and frankly on areas of disagreement’.[37] The Prime Minister and Foreign Secretary have often commented that the UK is an outlier in regard to its lack of dialogue with China vis à vis European and US allies.[38] The current UK government has restarted trade bilaterals and multiple senior ministers have visited the PRC and Hong Kong, marking a resumption in direct dialogue. These dialogues are seen as a chance to raise areas of ‘disagreement’, which might conceivably include incidents of transnational repression.[39]

59. However, it is important that the UK government does not refrain from taking appropriate action on transnational repression, including punitive measures such as imposing sanctions, in the name of maintaining dialogue. It is counterproductive for the UK government to make a commitment to raise human rights violations – under the heading of ‘disagreements’ – in bilateral meetings while taking no further action. Talking about such issues in high-level bilaterals, particularly in front of the cameras, is typically regarded by the Chinese Communist Party as hypocritical and ineffectual posturing. It does not help to strengthen relations nor secure concrete progress on the issue of human rights.

60. Conversely, taking further action, such as imposing targeted sanctions, does not necessarily impede the UK government’s goal of strengthening bilateral dialogue and pursuing growth. Evidence for this can be seen in the UK and other countries’ existing sanctions on PRC and Hong Kong companies for their role in facilitating Russia’s war effort in Ukraine. In response to these sanctions imposed by the UK, US, and EU, the PRC has issued critical statements ‘firmly opposing’ these actions and hinting at ‘negative effects’ on trade and diplomatic relations,[40]  but, in reality, the various countries involved have continued to meet with PRC officials and further action has been limited in scope.

61. Furthermore, taking concrete action on transnational repression, including sanctions, would signal that the UK is serious about its commitments to human rights and to Hong Kong under the Sino-British Joint Declaration. It would indicate consistency in the UK government’s approach and principles and would align the UK with our allies in North America and the EU.

(Feb 2025)