Asia Pacific Business Review

ISSN: (Print) (Online) Journal homepage: https://www.tandfonline.com/loi/fapb20

Geopolitics and Hong Kong as international

financial centre: a dynamic IPE perspective

Gregory T. Chin

To cite this article: Gregory T. Chin (2022) Geopolitics and Hong Kong as international
financial centre: a dynamic IPE perspective, Asia Pacific Business Review, 28:5, 660-679, DOI:
10.1080/13602381.2022.2127520

To link to this article: https://doi.org/10.1080/13602381.2022.2127520

Published online: 18 Oct 2022.

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ASIA PACIFIC BUSINESS REVIEW
2022, VOL. 28, NO. 5, 660–679
https://doi.org/10.1080/13602381.2022.2127520

Geopolitics and Hong Kong as international financial centre:

a dynamic IPE perspective
Gregory T. Chin
Department of Politics, York University, Toronto, Ontario, Canada

ABSTRACT ARTICLE HISTORY

This article examines the impact of US–China geopolitical tensions Received 5 March 2022
on Hong Kong as an IFC, and how Hong Kong is coping. Utilizing Accepted 19 September 2022
a dynamic IPE perspective, it details how Hong Kong officials, KEYWORDS
financial market actors and corporations have responded to the Hong Kong; international
punitive US measures against Hong Kong and China in 2020 and financial centre; United
2021, measures that are tantamount to commercial and financial States; China; National
warfare on China and the city, but also that work against the Security Law; resilience
interests of US corporates in Hong Kong. The analysis highlights
Hong Kong’s competitive resiliency as an IFC, from 2019 to early-
2022, and the sources of its resiliency.

Hong Kong plays an outsized role as an international financial centre (IFC) in supporting
the local economy and facilitating trade and investment throughout the Asian region. Its
banking assets are almost ten times its GDP, the equity market is 16-times, and assets
under management are 13 times (data from HKMA 2021b). Hong Kong is the third-largest
US dollar funding centre globally, and major profit centre for the most profitable US
investment and commercial banks, leading UK banks, and for US and European multi­
nationals. The city is the key offshore fund-raising centre for China’s leading firms looking
to go global, and the indispensable financial window for global companies looking to
enter or increase their presence in the Mainland (Li 2018, 2019). It is the leading offshore
hub for cross-border use of China’s currency, the renminbi, by a long shot.
But since the 2014 ‘Occupy Central’ protests, Hong Kong has been wracked by politics,
domestic and geopolitical. Internally, Hong Kong experienced social unrest on the streets,
with the peak in late 2019. Externally, geopolitical tensions between the United States and
China worsened significantly and spilled over into Hong Kong. 2019 and 2020 marked
a sharp escalation in financial and commercial tensions across the Pacific when US
politicians issued several new laws: the ‘Hong Kong Human Rights and Democracy Act’
(HKHRDA), which opened the way to revoking Hong Kong’s preferential treatment under
US law, requires the US government to impose sanctions on ‘those responsible for human
rights violations in Hong Kong’, and extends annual reporting requirements of US state
agencies on ‘matters of interest to the United States (US) in Hong Kong’, such as ‘limits to
autonomy’ in Hong Kong’s political situation (i.e. relations with Mainland China); and the
‘Hong Kong Autonomy Act’ (HKAA) which removed Hong Kong from its ‘special

CONTACT Gregory T. Chin gtchin@yorku.ca

© 2022 Informa UK Limited, trading as Taylor & Francis Group
 ASIA PACIFIC BUSINESS REVIEW 661

commercial treatment’ category, and paved the way for the US Treasury to impose
financial sanctions on Hong Kong and Mainland officials and banks that handle transac­
tions in US dollars for the sanctioned officials. These measures were presented as the
official response of the US to far-reaching political changes in Hong Kong. Hong Kong has
had to respond to the worsening geopolitical situation and the crossfire between the
Superpowers.
This article is part of the Special Issue in Asia Pacific Business Review, and it utilizes
a dynamic International Political Economy (IPE1) perspective to assess the impact of the
ongoing US–China geopolitical tensions on Hong Kong as an IFC, and how Hong Kong has
been coping. Many observers predicted doom and gloom for Hong Kong as a global
business hub and IFC when the city moved to implement the ‘National Security Law’ for
Hong Kong (NSL), and US authorities issued their measures to punish Hong Kong and
China (see, e.g. Tsoi and Cho Wai 2020; for a counter view, see, e.g. Stent 2020). When the
US Treasury issued financial sanctions in August 2020, Time magazine reported that
‘experts’ believed that the US sanctions are ‘not just a Hong Kong issue – they have
implications for every bank operating in the financial hub’ (Gunia 2020). The doom was
expected to be far-reaching for Hong Kong as IFC, considering that 78 of the world’s top
100 banks are present in the territory and potentially beyond, as the sanctions could apply
to banks anywhere in the world. A long-time academic China watcher (a vocal critic of
Beijing) has written that Hong Kong is ‘now coping with an exodus of talented people . . .
there has been a loss of business confidence related to the future of Hong Kong’ (Dreyer
2022).
In contrast to the doomsayers, Hong Kong’s Financial Secretary Paul Chan suggested
that revoking US preferential treatment would have ‘little impact’, that Hong Kong had
‘nothing to be afraid of’ (Chan 2020). Some observers in Washington also saw the US
measures as ‘self-defeating’ for the US when considering that Hong Kong was the source
of the largest bilateral US goods trade surplus in 2019 at US$26.1 billion (Mason and
Holland 2020 cite US Consensus Bureau data). Lardy at the Peterson Institute in D.C. called
the US measures ‘foreign policy as therapy’, i.e. ‘it makes you feel good, but it doesn’t have
any effect on the real outcome’ (cited in Lynch 2020). One notable IPE researcher
observed that Hong Kong’s competitive advantages as the two-way financial window
with the Mainland economy would likely persist despite the difficulties in 2019–2020 (Li
2020).
How accurate were the various predictions about the impact of the US measures on
Hong Kong as an IFC? How has Hong Kong responded, does it matter, and if so, how and
why? The First Section below details the US pressure which the Donald Trump presidential
administration and the US Congress imposed on Hong Kong and China in 2019 and 2020,
ostensibly, in response to the NSL – punitive legal measures and financial sanctions that
amount to ‘commercial warfare’ and ‘financial warfare’ on Hong Kong. The analysis turns
next in the Second Section to the actual impact on the IFC. The official data show that
Hong Kong as IFC was not fundamentally damaged or punished as a result of the US
measures. In fact, contrary to US intentions, the city’s financial market registered strong
growth in 2020 and 2021. The Third Section explores the main factors that account for the
positive outcomes in 2020 and 2021 for the IFC. Attention is given to two main factors. On
the one hand, the unintended consequences when the Trump administration and US
lawmakers issued two more commercial warfare measures targeting China in late 2020, to
662 G. T. CHIN

prevent US investment in China-based companies deemed to have ties with China’s

military, and to pressure China-based companies to delist from US Exchanges – and
when the Joseph Biden administration extended and expanded Trump’s measures in
June and July 2021. Contrary to US intentions, Hong Kong’s financial market turned out to
be the major beneficiary of these US actions when China-based corporates divested from
the US exchanges and sought alternative listings in Hong Kong; and large waves of non-
US capital flowed into the city. On the other hand, the strategic interventions of
Hong Kong officials were key to bolstering the resiliency of the city’s IFC after each
economic crisis over the last 25 years, and their key interventions in July and
August 2021 to influence central authorities to delay a vote on the adoption of China’s
new anti-sanctions law in Hong Kong.
The main argument is that the cumulative effect of the combination of punitive US
actions in 2019 and 2020 was not as intended by US politicians: Hong Kong’s financial
market and its status as IFC was not damaged; the China-based companies and their
market valuation were not undone; and Hong Kong officials and Mainland leaders did not
reverse the implementation of the NSL in Hong Kong. One could query whether the
Hong Kong-related and Mainland-focused economic warfare measures should be treated
‘together’, analytically.2 It is suggested here that a careful examination of the empirical
details will show the Trump administration and the US Congress treated Hong Kong and
China as interrelated policy and legal concerns and that Hong Kong was entangled with
the broader US attempt under Trump and Pompeo to rollback China’s global rise and
leading China-based companies. The methodology guiding the analysis is a dynamic IPE
perspective that examines the agency of US economic warfare measures on Hong Kong
and the Mainland in 2019 and 2020, and the actual effects of these actions when they
encountered existing structural conditions and variation in agency responses, particularly
of market actors in Europe, Asia and Mainland China, and policymakers and lawmakers in
Hong Kong and China: how this specific interaction of agencies and structure resulted in
intended and unintended consequences.3 A dynamic IPE approach allows for a nuanced
assessment of the impact on Hong Kong as IFC, including differentiating between short-
term, medium-term, and longer-term impacts, as well as direct and indirect effects on the
IFC. Due to word limits, this study will focus on the short-term direct impacts on
Hong Kong as an IFC from 2019 to early-2022, and only briefly addresses the potential
medium- and long-term implications.

US pressure
Initially, the Trump administration differentiated its treatment of Hong Kong from the
Mainland even as US authorities toughened their positioning on China. But this changed
in 2019 after the proposed Hong Kong extradition bill and when China commenced with
the preparation of the NSL in response to the intensifying social protest in Hong Kong.

Putting Hong Kong under pressure: declared intentions

For the purposes of this article on Hong Kong as IFC, it is useful to distinguish between the
US actions on the Hong Kong economy more broadly, such as the revoking of special
economic treatment, and the US measures that are targeted at the financial sector in the
 ASIA PACIFIC BUSINESS REVIEW 663

city, such as the financial sanctions; as well as to differentiate between the actions that are
immediately impactful on the IFC versus those of more medium-term relevancy.
The relevant US actions on Hong Kong started with the US Congress passing the
HKHRDA in November 2019, and President Trump signing it into law one week later (US
Congress 2019). The HKHRDA amended the 1992 ‘US-Hong Kong Policy Act’, to require
the State Department to annually certify whether Hong Kong is sufficiently autonomous
from Mainland China to warrant ‘different and preferential treatment’ under US law, but
importantly for Hong Kong as IFC, the Act opened the way for the US government to
impose sanctions on foreign individuals for ‘undermining freedoms and autonomy’ in
Hong Kong.
On 27 May 2020, the day before China voted on the adoption of the NSL for
Hong Kong, US Secretary of State Michael Pompeo declared that the State Department
deemed Hong Kong was no longer sufficiently autonomous from Mainland China, and so
no longer warranted favourable and distinct treatment apart from the Mainland under US
law (US Department of State 2020a). Economically, this meant the end of Hong Kong
goods being exempt from US tariffs on Mainland China, the punishing tariffs in Trump’s
trade war with China, and the end of the exemptions on US dual-use technology exports
to Hong Kong. Two days later (29 May 2020), President Trump outlined the agenda in full:
‘I am directing my administration to begin the process of eliminating policy exemptions
that gave Hong Kong different and special economic treatment’ (Trump White House
Archive 2020). Such sweeping measures put pressure on the city, broadly, as a global
business and trading hub, and created uncertainty about whether the city can continue its
established roles.
In the same May 2020 ‘Remarks by President Trump on Actions Against China’, Trump
also outlined his Administration’s ‘national security’ justifications for hitting at China, and
how the punishment of Hong Kong was part of the broader US geostrategic pushback
against China under Trump’s lead. Trump accused ‘the government of China’, ‘for years’ of
conducting ‘illegal espionage to steal our [USA] industrial secrets . . . ’ Trump also noted to
the media that he was readying to bar Chinese companies listed on US financial
exchanges for not abiding by US accounting and audit standards (BBC News 2020).
Meanwhile, US lawmakers fast-tracked the ‘Holding Foreign Companies Accountable
Act’ (HFCAA) to bar trading in any shares of a company that is unwilling to be inspected
by the Public Company Accounting Oversight Board (for three consecutive years).
On 1 and 2 July 2020, the two houses of Congress unanimously passed the ‘Hong Kong
Autonomy Act’ (HKAA) (US Congress 2020a), which provided the legislative groundwork
for US authorities to impose asset-blocking and other unilateral sanctions on banks and
other financial institutions which ‘knowingly conduct significant transactions’ with indi­
viduals deemed by the US to have ‘materially contributed’ to the erosion of Hong Kong’s
autonomy, and to seize their property and assets ‘in the US or in the possession or control
of US persons’ (US Congress 2020a; US Department of the Treasury 2020). The statute
requires the Secretary of State to submit a Report to Congress that identifies foreign
persons and entities who ‘materially contributed to the failure of the Government of
China to meet its obligations under the Joint Declaration or the Basic Law’. The HKAA also
targets ‘Foreign Financial Institutions’ (FFIs) that assist ‘Material Contributors’, and
requires the US Treasury Department to impose sanctions on FFIs that knowingly con­
ducted a ‘significant transaction’ for a sanctioned foreign individual. The Treasury
664 G. T. CHIN

Secretary is also required to submit a separate Report to Congress that identifies any FFI
that ‘knowingly conducts a significant transaction’ with a Material Contributor (‘Identified
Institutions Report’). President Trump signed the HKAA into law on 14 July 2020. The
same day, Trump also signed ‘Executive Order [EO] 13936’ on Hong Kong normalization,
to formally rescind America’s ‘special status’ treatment of Hong Kong as distinct from
Mainland China (Trump White House Archive 2020a).4
According to legal experts (Chan 2020), the HKAA expanded the range of foreign
individuals that could be subject to US sanctions, enabling the US president or govern­
ment to impose sanctions on FFIs. Trump officials were aware that 78 of the world’s
leading 100 banks are present in the Hong Kong and positioned strategically to provide
services to international firms seeking to do business with China, and to Mainland
Chinese companies transacting with the outside world. They were also aware that
1350 US multinationals have offices in Hong Kong, the Hong Kong stock market had
more than 2100 listed companies with a total market value of about US$4.4 trillion (as of
May 2020). Bloomberg reported that ‘a top [Trump] administration priority has been
finding ways to punish banks based in Hong Kong’, i.e. banks writ large, that are willing
to implement the NSL (Wadhams et al. 2020). Advisors to the Trump administration
proposed financial warfare options against Hong Kong (and China) that included the
‘nuclear’ option of barring banks in Hong Kong and even the local monetary authority
(HKMA) from accessing US dollars and the dollar payment system. In early June 2020,
Pompeo lashed out at global banks for doing ‘corporate kowtows’ to Beijing (US
Department of the Treasury 2020). The Trump administration considered different
options for pressuring and punishing Hong Kong as an IFC, and to ultimately promote
decoupling of the US-Hong Kong/China financial sectors and the US and China’s
economies, and to reduce the involvement of US banks in the China-led Belt and
Road Initiative (for example, Citibank, see Sweeney 2020).
However, Trump was alerted to the potential unravelling of the US dollar’s global
standing that could result from an outright currency war. Equally, if not more significant,
the commercial interests of Wall Street and other US banks in Hong Kong, and of US
multinational corporations and SMEs in Hong Kong swayed US decision-makers towards
measured sanctions. US Treasury did the cost-benefit calculations of US economic inter­
ests in Hong Kong and warned against the nuclear option. Eventually, US politicians
settled on starting with sanctions against Hong Kong and Mainland officials and punish­
ing the banks and corporates in Hong Kong that handle significant transactions for the
sanctioned individuals. Of direct impact, on 7 August 2020, the US Treasury Department
sanctioned Hong Kong chief executive Carrie Lam and 10 Hong Kong and Mainland China
officials for the erosion of autonomy and freedom of expression (US Treasury Department
2020). These actions were taken

pursuant to Executive Order 13936 . . . which . . . declares a [USA] national emergency with
respect to the situation of Hong Kong . . . also builds on . . . the Hong Kong Human Rights and
Democrat Act of 2019 and the Hong Kong Autonomy Act of 2020.

US Treasury Secretary Steven Mnuchin voiced the Administration’s intended consequence

(READ: punishment) from the Treasury angle: ‘The US stands with the people of
Hong Kong’, and ‘we will use our tools and authorities to target those undermining
their autonomy’ (US Department of the Treasury 2020).
 ASIA PACIFIC BUSINESS REVIEW 665

Consequences: intended and unintended

The mantra of the Trump administration and US legislators was that they were revoking
the special status for Hong Kong and imposing sanctions on Hong Kong and Mainland
officials to protect US national security and to ‘hold China accountable for its aggressive
actions against the people of Hong Kong’. But Trump remarked when he issued EO 13936:
‘If . . . . . . changes in China’s actions ensure that Hong Kong is sufficiently autonomous to
justify differential treatment in relation to the PRC under US law, I will reconsider the
determinations made and actions taken and directed under this order’ (Trump White
House Archive 2020a). The stated intent was to induce change in the Chinese leadership’s
behaviour regarding the governance of Hong Kong by pressuring them to reverse and
undo the implementation of the NSL.
Where the intention of the US actions was about protecting US national security by
causing major disruption in global supply chains, pushing-back against China’s leading
technology companies, engendering sustained decoupling of the US and Chinese econo­
mies and undoing the transnational links between the two societies – and Hong Kong’s
hub status within these international networks – then the Trump administration and US
politicians did achieve the start of their intended goals. Moreover, their multi-layered
actions will not be easily reversed by their successors, as can be seen in the decisions of
the Biden administration to date (detailed below). The revoking of the special status did
result in the banning of US exports of ‘sensitive technologies’ and the end of cooperation
between US and Hong Kong officials in these issue-areas; obstacles to flows of commerce,
people and money between the US and Hong Kong; punishing tariffs on Hong Kong
exports; and banks froze the US dollar assets of the sanctioned Hong Kong and Mainland
officials. Such measures did raise questions about whether Hong Kong could continue to
play its established role as a trade and innovation hub, and concerns were raised among
the foreign and local business communities. A chill went through Hong Kong’s business
community, especially US financial institutions and companies in Hong Kong (BBC 2020;
Gunia 2020). From these angles, one could say that the US measures achieved their
intended effects.
However, the US measures did not achieve their intended effects in terms of affecting
outcomes in Hong Kong in two key respects. First, if we consider that the ultimate self-
stated objective of the HKHRDA, the HKAA, and Executive Order 13936 was to not only
‘target’ and ‘hold accountable’ Chinese and Hong Kong officials for their supposed wrong-
doing but to pressure Beijing and Hong Kong to reverse course on the enactment of the
NSL, then not only did China and Hong Kong officials not reverse the NSL, rather they
responded to the US actions by speeding up the implementation of the NSL. There was no
give-in to the US pressure. Hong Kong officials denounced the US actions. There was and
is no walk-back by Beijing or Hong Kong.
Second, Hong Kong’s trade and exports rebounded and surged in 2021, making
a robust but uneven recovery in 2021 and into early 2022 despite the city’s removal of
US ‘special economic treatment’. Even the US International Trade Administration under
the US Commerce Department admits (2022) that “Hong Kong remains a popular destina­
tion for US investment and trade . . . Hong Kong’s economy, with world-class institutions
and still comparatively robust regulatory systems, is bolstered by its competitive financial
and professional services, trading, logistics and in normal non-pandemic times, tourism’.
666 G. T. CHIN

From the perspective of the immediate term at the least, the US decision to revoke
preferential treatment had limited effect on the city’s economy and trade. In an interview
with China’s official media, Financial Secretary Chan observed that Hong Kong products
made for export to the US ‘accounted for less than 2% of the city’s overall manufacturing’,
worth only about HK$ 3.7 billion, and less than 0.1% of the city’s overall exports (Chan
2020). The impact of the US measures would be limited because Hong Kong’s economy is
dominated by the services sectors. Chan further emphasized that Hong Kong has enough
ammunition to defend its Linked Exchange Rate System (LERS, i.e. linked to the US dollar),
citing the city’s large holdings of US currency reserves. Importantly, Chan underlined that
Hong Kong officials had ‘talked to the People’s Bank of China’, and that China’s central
bank ‘will be able to extend us unreserved support in defending our currency [Hong Kong
dollar-US dollar peg]’ (Chan 2020; Xinhua New Agency 2020). Another measure that Chan
alluded to was Hong Kong potentially bolstering its status as an independent tariff zone
via the World Trade Organization (WTO) where it is a full member as ‘Hong Kong, China’,
as supported by the Mainland (see Vic Li’s article in this collection). Since 1997, the city has
already been enjoying ‘special status’ with various other trading partners, as a separate
customs territory from the Mainland, with zero-tariff trade.
In some respects, the financial sanctions did achieve some of the stated intentions as
legal tools: banks in Hong Kong, especially US banks, and banks elsewhere in the world
understand they are no longer allowed to complete transactions for the officials on the
sanctions list under US law (Gunia 2020). A lawyer who specializes in economic sanctions
at Steptoe & Johnson in Hong Kong confirmed in August 2020 that every bank in
Hong Kong would have put in place their sanctions compliance measures, and
Bloomberg reported this happened immediately with US banks (Nick Turner is quoted in
Gunia 2020). According to an American lawyer at the law firm Hogan Lovells in Hong Kong
(and a former assistant general counsel at the Office of the USTR), other (non-US) global or
regional banks or Chinese banks are still technically allowed to transact with the officials
in Hong Kong dollars or RMB. They can try to avoid US sanctions as long as US citizens or
US dollars are not involved in the transactions – however, they do face the risk of future
sanctions (Benjamin Kostrzewa quoted in Gunia 2020). Legal specialists note that what
makes the sanctions from the US Treasury potentially impactful for the ‘IFC as a whole’ is
that although the sanctions are imposed on specific individuals, they also have broader
implications for every bank, financial institution and company operating in Hong Kong in
particular, but also potentially elsewhere in the world, in London, Sydney or Singapore,
that possibly handle a US dollar transaction, or a transaction involving US individuals or
entities, on behalf of the sanctioned Hong Kong or Mainland officials and their families
into the future. The HKAA requires the Material Contributors Report to be updated,
ongoing, and resubmitted annually, and more individuals and entities could be identified
as Material Contributors in the future. According to one law firm (cited in Chan 2020), the
HKAA defines ‘material contribution’ in general terms as any action that reduces the
autonomy of Hong Kong or prevents people in Hong Kong from enjoying certain rights
and ‘democratic’ processes. The HKAA targets FFIs that assist Material Contributors, and
the Treasury Secretary is required to submit a separate report to Congress identifying any
FFIs that ‘knowingly conducts a significant transaction’ with a Material Contributor. Any
expansion in the State Department’s ‘Material Contributors’ list could be followed by
additions to the FFIs list. As a result, non-US FFIs in Hong Kong and elsewhere in the world
 ASIA PACIFIC BUSINESS REVIEW 667

risk being targeted in the future under the HKAA (Gunia 2020). It is not accidental if
reputational damage is caused over the medium term; if perceptions about Hong Kong as
a ‘well governed’ financial centre are negatively affected. But what has been the actual
outcome, in the immediate term?

Actual outcomes as IFC

Focusing on 2020–2021, when the US penal actions against Hong Kong were imposed
and thereafter, the official data (from the HKMA) does not show capital fleeing
Hong Kong, nor wealth leaving Hong Kong, financial institutions leaving, nor that
Hong Kong’s capital market receded. In fact, Hong Kong’s financial market recovered
and returned to growth in 2021 in five key dimensions. First, money did not flee
Hong Kong to accounts in other financial centres; one does not see capital flight nor
withdrawal or relocation of financial institutions from Hong Kong in 2020 or 2021. Quite
the opposite, the amount actually increased from 2019 to 2021, with total assets under
management in Hong Kong at HK$ 28 trillion.5 The HKMA reports that, during the “last-
two challenging years [2019, 2020], deposits in the Hong Kong banking system grew by
8.5% (Kong Monetary Authority 2021a).
Second, the exchange rate of the local currency of Hong Kong did not experience major
depreciation. In February 2021, the HKMA reported that the Hong Kong dollar had stayed
strong against the US dollar, reflecting continuous fund inflows, not outflows, as some
had feared. In December 2021, the HKMA chief executive reported that the ‘Linked
Exchange Rate System’ (HK dollar-US dollar pegged exchange rate) remained ‘rock
solid’ throughout the period of ‘testing times’ (Kong Monetary Authority 2021b).
Third, in December 2021, the HKMA reported that capital and liquidity levels remained
well above global standards; that loan quality and profitability compared favourably with
global peers (Kong Monetary Authority 2021b). Banks in Hong Kong used the ‘buffers’
built-up when the economy was strong to provide timely financial support to corporates
and households during ‘these stressful times’. The HKMA also ensured that financial
institutions comply with the banking stability and macroprudential standards in the
Basel II and III requirements, and Financial Stability Board norms and standards. The
HKMA reported that the capital strength, liquidity position and non-performing loan
ratios of the Hong Kong banking sector compared favourably with ‘international peers’,
i.e. banks in financial centres, such as London, Singapore and New York.
Fourth, robust growth in Hong Kong’s asset and wealth management sector from 2019
to 2021. The assets under management in Hong Kong grew by a significant 20% in 2019,
throughout the period of intense social unrest, and growth remained strong into 2020.
Banks in Hong Kong conveyed to the HKMA that growth was sustained into 2021, even
during the COVID-19 period. The quantity of existing and potential credit risk associated
with the loan and investment portfolios – asset quality rating – in Hong Kong’s banking
system appears well managed, according to the International Monetary Fund (2022).
Fifth, the growth of the Hong Kong Exchange remained strong in 2020, with IPOs
totalling US$ 400 billion. From January to April 2021, IPOs raced ahead to $130 billion.
Hong Kong’s IPO market has ranked number one for 7 years in a row; marking an eightfold
increase, year-on-year, period to date. In 2020, Hong Kong’s main board ranked second,
just behind NASDAQ for IPOs; companies raised over US$50 billion from IPOs, a year-on-
668 G. T. CHIN

year jump of 27% (Cheng and Cheung 2021). According to Financial Secretary Chan
(May 2021), new listings amounted to one-quarter of total market capitalization on
HKEX.6 Daily turnover on HKEX grew from $80 billion per day in 2019, to $130 billion in
2020, to $200 billion in 2021. The growth of the Stock and Bond Connect Programs
contributed strongly to these gains.

The competitive resiliency of Hong Kong IFC: key factors

A number of factors accounted for the growth in Hong Kong’s financial sector and
financial markets in 2020 and 2021, and we focus on two factors that stand out from an
IPE perspective: the unintended consequences of Trump’s EO 13959 (November 2020)
and the HFCAA that was signed into US law (December 2020); and the strategic interven­
tions of Hong Kong officials to bolster the resiliency of the IFC, and shield it from the
intensifying geopolitical crossfire.7

Financial warfare on Mainland China: unintended effects

After losing the 2020 presidential election, Trump, his administration, and US legislators
moved rapidly on their threats to target the US financing of Chinese companies with
purported links to China’s military by banning US investment. On 12 November 2020,
Trump signed EO 13959, ‘Addressing the Threat from Securities Investments that Finance
Communist Chinese Military Companies’ (Trump White House Archive 2020b), to make
effective on 11 January 2021, that US persons are prohibited from purchasing any publicly
traded securities or derivatives of ‘Communist Chinese military companies’ identified by
the US government. A wide swath of Chinese corporate entities and industries were
subject, including Huawei, China Spacesat, China Mobile Communications Group
(Greenberg Traurig 2021).
In December 2020, Trump then signed into law the HFCAA, to clear the way for the US
Securities and Exchange Commission (SEC) to remove foreign companies from US
exchanges if the companies do not comply with US auditing oversight rules within
three years (US Congress 2020b). The Act requires companies to establish they are not
owned or controlled by a foreign government and are willing to allow the US Public
Accounting Oversight Board (PAOB) to review their financial audits. While the legislation
applies to any company from any foreign nation, the Act was essentially aimed at PRC-
based companies that US authorities deem a threat to US national security. Under the Act,
the targeted companies have three years to comply with the PAOB requirement or be
forced to delist from US exchanges.
We focus here on the effects on the Hong Kong Exchange, its total market capitaliza­
tion, IPOs, and the market valuation of indicative firms. US fund managers such as
BlackRock, the world’s largest asset manager, did respond to Trump’s EO 13959 by selling
some of the assets deemed to have links with China’s military in November 2020, but
details on their divestments are scant. Vanguard Group, a US-registered investment
advisor with about US$7 trillion in global assets under management (January 2021),
and the world’s largest provider of mutual funds and the second-largest provider of
exchange-trade funds (ETFs) after BlackRock, and Nuveen, the US$ 1.1 trillion asset
manager for the New York-based Teachers Insurance and Annuity Association (TIAA8),
 ASIA PACIFIC BUSINESS REVIEW 669

each scrambled to sell, though they have not released any details on exactly which stocks
they sold (Shen and Westbrook 2021; Arnold 2021). Stock market filings showed that
BlackRock sold almost all its stake in China Telecom in mid-January 2021.
However, the US measures on China in late-2020 also gave rise to unintended con­
sequences. Even before the HFCAA was passed by Congress and signed into law by
Trump, in late 2020 a number of Chinese companies (such as Alibaba, Netease and Yum
China) anticipated the legislation, and they pursued secondary listings in Hong Kong as
a hedge against the potential ban from trading their shares in the US. Hong Kong’s Stock
Exchange finished the year 2020 as the world’s second-largest IPO market after raising
a total of US$50 billion in new listings, much in the second half of 2020 (according to
KPMG data, cited in Olsen 2020).
Equally striking, as US asset managers divested their PRC holdings in late 2020 and
early 2021, in response to EO 13959, other global investors surged in to buy the sanc­
tioned Chinese firms. Reuters (Shen and Westbrook) reported in January 2021 that Asian
and European investors were swooping in and snatching discounted stocks of the
Mainland companies in Hong Kong, targeted by the US investment ban and delisting
pressures. The same week Vanguard and BlackRock announced their divestments, cash
poured in to lift the Hong Kong-listed shares of Chinese telecoms by more than 15%.
Swiss investment bank UBS remarked that clients were interested in taking advantage of
the US sell-off. As a result, in early 2021, China Mobile had its best week in 12 years;
Chinese state energy company CNOOC was up 16%, and chipmaker SMIC up 10%. All
three were targets of the US sanctions and faced removal from the NYSE and from US-
anchored global indexes.
UBS head of China strategy, Wendy Liu (quoted in Shen and Westbrook 2021), sug­
gested in January 2021 that it was ‘worth monitoring the market closely . . . because there
will be forced liquidations’, but also that, ‘We do have European investors interested in
stocks blacklisted by the US’. The head of Asia multi-asset quant solutions at France’s BNP
Paribas Asset Management Paul Sandhu remarked, ‘I think the fundamentals don’t
change. They’re still sound. The burden of these sanctions has really fallen on US investors’
(quoted in Shen and Westbrook 2021).
The South China Morning Post (Zhang 2021) reported in February 2021 that money
gushed into the city’s stock market during the first month of the year. According to a chief
investment officer at Invesco (with US$ 1.35 trillion of assets under management), ‘more
Chinese companies are seeking IPOs and secondary listings in Hong Kong, given tigh­
tened regulations in the US . . . They represent great investment opportunities’. Given the
US investment restrictions on the NYSE, the Mainland’s pension managers, asset man­
agers, investment funds and wealth advisors focused on Hong Kong-traded stocks.
According to Bloomberg data, Hong Kong’s market capitalization of US$ 7.25 trillion put
it ahead of Japan.
Hong Kong’s role as the key gateway for Mainland and offshore funds seeking
a springboard to Mainland Chinese stocks, and for offshore money looking to invest in
profitable China-based companies was reinforced. Mainland funds bought Hong Kong
stocks at an unprecedented rate, with inflows from the Mainland in January 2021 equiva­
lent to 55% of the total trading volume on HKEX for 2020. As of the end of January 2021,
Mainland enterprises already accounted for 52% of the 2,545 listed companies in
670 G. T. CHIN

Hong Kong, and 81% of the market capitalization and 90% of the trading volume on HKEX
(Zhang 2021).

Hong Kong Agency: intentional interventions

Writing in the aftermath of the 2008–09 financial crisis, the IPE scholar Pauly (2011) stated,
‘geography continues to shape the character and promise of Hong Kong’s financial sector. Its
physical and human links to the heartland of China made it a natural centre for trade in goods
and services’ (Pauly 2011, 1). Pauly added, however, that ‘nothing was inevitable’ about the
precise path that Hong Kong took into the leading tier of IFCs, that ‘state policy decisions
played a key role in shaping the city’s market’, and that for the City to retain its ‘top-tier
position will require a more active role for government than has been the norm . . . ’ Pauly’s
point about the need for active local governmental intervention has proved prescient.
Over the past 25 years, Hong Kong officials have acted at various instances to ‘buffer
the city as an IFC’, each time Hong Kong’s financial system has been severely tested: the
1997–98 Asian financial crisis; the SARS pandemic in 2002–03; the 2008–09 great financial
crisis; and the recent ‘triple whammy’ of social unrest, geopolitical tensions, and the
COVID-19 pandemic. Hong Kong’s authorities ‘do not take for granted’ the city’s resiliency
as an IFC.
The official position on Hong Kong’s resiliency strategy is for the city to be
a ‘responsible stakeholder in a highly interconnected global financial system’, ‘where so
much depends on the stability of IFCs’ (Kong Monetary Authority 2021b). To achieve this
goal, the HKMA has focused on:

● Putting in place mechanisms to closely monitor market developments and

behaviour
● Continually improving the regulatory regime to mitigate risks in the financial system
● Building buffers and planning for contingencies on sunny days, and swiftly imple­
menting contingency plans when storms appear
● Contributing to policy deliberation and standard setting at international regulatory
forums

There are, however, other unique elements to the most recent Hong Kong IFC resi­
lience story, concerning how the city has dealt with societal tensions, severe public health
challenges, and intensifying geopolitical rivalry. Hong Kong officials undertook robust
public communications, conducted surveys on corporate opinion and analysed the data,
and liaised with globally influential third-party evaluators, including UN agencies, the IMF,
and global financial centre indexers. Due to word limits, we will only detail how local
officials further responded to the geopolitical pressures in 2021, to try to shield
Hong Kong from the ongoing US–China crossfire, especially after the Biden administration
extended the Trump administration measures, including the financial sanctions in
Summer 2021.
Hong Kong officials intervened to tamp-down geopolitical retaliation after the Biden
administration added fuel to the US–China geopolitical fire in June and July 2021.
President Biden stoked Beijing’s ire when he signed EO 14032 on 3 June 2021, which
expanded the scope of Trump’s EO 13959 and added other charges (US Federal Register
 ASIA PACIFIC BUSINESS REVIEW 671

2021: 30145–30147). EO 14032 continued the ban on US citizens from buying the publicly
traded securities of any entity deemed by the US Treasury Secretary (in consultations with
the Secretaries of State and Defence) to be operating in the defence and related materials
sectors or the surveillance technology sector of Mainland China.9 But China’s national
authorities had been preparing more forceful legal measures since at least late 2020 to
directly counter the US sanctions. On 10 June 2021, the SC of the NPC approved the new
‘Anti-Foreign Sanctions Law’ (Xinhua News Agency 2021a). The new legislation was used
immediately to impose sanctions on seven US nationals, including former Trump officials.
The new anti-sanctions law gives government authorities broad powers and legal tools to
seize or freeze assets from entities that abide by the US sanctions.
The Biden administration countered on 7 July 2021, when Biden extended Trump’s EO
13936 for ‘another year’ (The White House 2021), based on the rationale that the threats to
the US continued. On 15 July 2021, an official warning was sent to US companies about
their safety operating in Hong Kong due to China’s NSL and China’s new anti-sanctions
law, charging that their data is increasingly subject to Mainland monitoring, their execu­
tives are vulnerable to detention, and their corporate operations at the mercy of China’s
justice system (US Department of State, US Department of the Treasury, US Department of
Commerce, US Department of Homeland Security 2021). Finally, on 16 July 2021, another
seven PRC officials were sanctioned for purportedly violating Hong Kong’s autonomy and
freedoms (Blinken 2021).
Some local market analysts gave a ‘collective shrug’ to the July 2021 sanctions
(Magnier 2021). However, the preparations for the NPC vote to approve the adoption of
the new anti-sanctions law into Hong Kong law, scheduled for August 2021, raised
concerns among businesspeople and legal experts in the city. The EU Chamber of
Commerce emphasized that the way the new law passed rapidly was not reassuring to
European companies which were increasingly feeling like pawns in a geopolitical game
(Tian 2021). The foreign business community was concerned that the enacting of the new
anti-sanction in the City would force companies to pick sides and choose which regula­
tions to follow (China or USA). In mid-August 2021, Reuters (John and Murdoch 2021)
reported that senior executives of the biggest financial firms in Hong Kong tried to reach
Hong Kong financial secretary Chan to register their ongoing concerns and to ask for
details as the NPC headed towards the vote. In response, HKSAR officials met with
representatives from the business chambers and banks during the first two weeks of
August, to hear their concerns as local lawmakers prepared the matching local legislation
(Cheng and Cheung 2021).
An unexpected breakthrough came on 20 August 2021 when China’s top legislative
body ‘unexpectedly postponed’ the vote to introduce the far-reaching anti-sanctions law
in Hong Kong (Cheng and Cheung 2021). The statement from the Hong Kong government
did not explain the delay but did state: ‘the NPC and its Standing Committee, as the
country’s highest authority, make decisions on Hong Kong matters based on the city’s
interest. The government will fully support, implement and cooperate [with the deci­
sions]’. The HKGCC welcomed the postponement as ‘more time is needed to listen to and
fully understand the views and concerns of the business sector’, and the Hong Kong
American Chamber of Commerce (1400 members) also welcomed the delay with
Chamber vice president Tara Joseph saying, ‘AmCham very much hopes that the inter­
national business community is part of the dialogue so we can all work together to
672 G. T. CHIN

support Hong Kong as the premier destination in China for global businesses’ (quoted in
Cheng and Cheung 2021).
All signs point to Hong Kong officials persuading Beijing behind closed doors to
delay or postpone the NPC SC vote. The South China Morning Post reported that local
lawmakers in Hong Kong conveyed to central authorities there was deep apprehension
among foreign investors and businesses about the new law, and that Hong Kong
financial officials would need more information from Beijing before further consulta­
tions could resume (Cheng and Cheung 2021). The Post further reported that one
unnamed Mainland source indicated that potential backlash from banks – even some
of China’s state banks – was one of the key factors for the postponement (Cheng and
Cheung 2021). The official explanation from Mainland sources was that the central
government ‘hopes to listen to further views on the matter’ and ‘do more legal research’
(Cheng and Cheung 2021).
The decision to delay arguably represented a return of the Central Government to
the ‘One Country, Two Systems’ (OCTS) formula in handling Hong Kong as a global
business hub, after the enactment of the NSL. In other words, that Beijing returned to
taking a largely ‘practical and functional approach’ to Hong Kong as an IFC, consider­
ing that Hong Kong is still the leading IFC for China up to the current moment (despite
the advances in Shanghai and Shenzhen’s financial markets), and that it makes rational
sense for Beijing to maintain the OCTS framework to make optimal use of the SAR as
an international financial hub (呂大樂 [Lui Tai-lok] 2020; Lui forthcoming). For
Hong Kong as IFC, this means Central-local compromise and give-and-take where
core elements of regulatory autonomy and Hong Kong’s legal and regulatory distinc­
tiveness such as its Basic Law, and areas of commercial law, contract law, customs law
are maintained for the global business hub even as Hong Kong integrates further with
the Mainland in terms of national security, and at the local community and personal
rights level.
Local market conditions at the time of the delay on the anti-sanctions law were
also likely a factor in that the Hang Seng Index was facing downward pressure in
Summer 2021, and the HK dollar was facing selling pressure at that time (Lindberg
2021). Hong Kong’s financial markets were battered in late Summer 2021 due to
central government clampdowns on sectors ranging from high tech, gaming,
Mainland property development, to private foreign education services. Finally,
Hong Kong’s strict adherence to Beijing’s zero-COVID policy has meant an ongoing
lockdown of the city, no border reopening, no substantial financial injection from
inbound Mainland tourism, and growing frustration from foreign financial institutions
and foreign corporates.
Hong Kong’s key intervention in July–August 2021, and the suspension of the NPC
vote gave the Biden administration some time to rethink the effectiveness of the
Trump measures, and the US Treasury and Commerce Departments more time to
consider the costly effects of the economic and financial war on Hong Kong. It is
noteworthy that the Biden administration did not issue further statements, sanctions,
or penalties related to Hong Kong from July 2021 until late June 2022 (in contrast to
Xinjiang).
 ASIA PACIFIC BUSINESS REVIEW 673

Theoretical implications
This article makes two theoretical-conceptual contributions to the academic literature on US
economic warfare and sanctions. First, to advance the study to advance the study of US
economic warfare, conceptually, to the unique case of ‘One Country, Two Systems’, which is
specific to Hong Kong, China. Scholars have long studied how states have used economic
warfare – economic blockades of another nation’s supply of essential goods, trade or
investment embargoes, or even bombing of the enemy state’s industries – to cause
economic pain and change in the enemy’s behaviour (Burk 1982; Offer 1989; Bollard
2020). In IPE and Security Studies, scholars have examined how financial and monetary
statecraft, and international financial and economic relationships can be weaponized by
states as instruments of coercive power to affect the behaviour of other states, in the service
of national security objectives (Baldwin 1985; Kirshner 1997). International Relations scholars
have shown how the Trump administration was particularly avid practitioners of ‘weaponiz­
ing interdependence’, and keen to use economic leverage to extract concessions from other
nations across a wide array of economic and security fronts (Farrell and Newman 2019;
Drezner 2019). Trump’s trade war with China was one of the most obvious examples of such
international behaviour, and it expanded quickly from the pursuit of trade concessions into
other areas, namely, investment controls, export controls to prevent Chinese acquisition of
leading-edge US technology, and national security campaigns and visa controls to root out
purported cyber espionage, and undo scientific cooperation (Chin 2018; 427; Chin 2021).
The ultimate goal of Trump’s economic warfare was to restore US supremacy, i.e. ‘make
America great again’, and do so by roll-back of China’s global rise. The analysis above details
the specifics of the Hong Kong-related aspects of the US economic warfare on China, and
the links to the broader Trump era rollback measures on China, and the response of
Hong Kong and Mainland officials, and of market actors and businesses to the US measures.
Second, the approach taken to examining the responses to the US economic warfare draws
on the social science tradition of differentiating between intended and unitended conse­
quences, anticipated and unanticipated effects and outcomes; a dynamic IPE perspective to
highlight the net effects of the US measures. On balance, Hong Kong as IFC was not damaged
by the US actions, even if the sanctioned officials and their families have been somewhat
inconvenienced by the sanctions. Moreover, the dynamic IPE approach further finds that if the
goal of the Trump administration was to try to protect Hong Kong’s autonomy (and this is
an ‘if’), then its actions failed. The punitive US measures have only pushed Hong Kong and the
Mainland closer together. Prior to the social unrest, the US sanctions, and COVID-19,
Hong Kong was already pursuing game-changing structural transformations to try to capture
the opportunities of the ‘IFC of the future’ (Guo 2021). The US moves have only sped up the
medium-term trend of Hong Kong seeking closer integration with the Mainland economy via
the ‘Guangdong-Hong Kong-Macao Greater Bay Area’ Plan (The Government of the HKSAR
2021). The dynamic IPE approach alerts us to the significance of not only the intended but also
the unintended consequences of the punitive geopolitical actions.

Practical implications
As of Summer 2022, despite the lose-win nature of the US–China economic warfare, in
China’s favour, the US is again applying geopolitical pressure that demands the attention
674 G. T. CHIN

of Hong Kong officials, as Washington has recently expanded its Russia-related sanctions
by including more China-based entities and a Hong Kong-licenced company on its
sanctions lists (US Federal Register 2022: 38921). Officials in Beijing and Hong Kong
must plan responses to further potential US financial and currency warfare actions. In
May 2022, HKMA chief executive Eddie Yue suggested that the HKMA and the local
banking sector have already prepared emergency plans for managing potential risks in
different ‘extreme situations’ if Hong Kong is affected by the Russia–Ukraine conflict, such
as if the US and its allies freeze Hong Kong’s overseas assets (FOREX reserves) or if the
financial hub is denied access to the SWIFT system (Pao 2022a). The HKMA has commu­
nicated with China’s central bank on ensuring liquidity for the IFC, and for maintaining
external trade and financial operations in an extreme scenario of currency warfare, i.e. the
‘nuclear option’, discussed above.
In early June 2022, Financial Secretary Chan wrote in his blog that the ‘recent Russian-
Ukrainian conflict has made it clear how the US has weaponized the dollar and some
international financial systems to openly distort and interfere with the operation of global
financial markets’, and the city now has to plan the future from the perspective of
safeguarding national security, and make emergency plans with a ‘bottomline mentality’
(Pao 2022b). One measure is that Hong Kong has recently further simplified its listing rules
to welcome the US-listed ‘China concept stocks’ that are seeking a second listing ‘due to
political concerns’ – this move harkens back to the secondary listings and waves of capital
that streamed into Hong Kong in late 2020 and 2021 detailed in the above sections. Chan
further warned corporates in the city that ‘security is not only a national concern, but also
a risk that companies must carefully assess’ (Pao 2022b). This can be read as a cautionary
warning to local companies and to global companies and foreign financial institutions
that local officials may need to take tougher measures in the next while to safeguard
Hong Kong’s interests as well as China’s national security interests. Managers, executives,
and professionals in Hong Kong will need to be more proactive in adapting to the
growing geopolitical risk at the regional and global levels. It would also be helpful for
US banks and US corporates that remain heavily invested in Hong Kong to be more
forceful in encouraging US (and Chinese) leaders to meet face-to-face to discuss ways to
mitigate and reduce the US–China geopolitical tensions, and to walk-back the economic
warfare. Although the current political climate in Washington, DC makes this a difficult
goal, it is the only way to end the current worsening scenario.

Conclusion
The discussion above has analysed how the geopolitical tensions between the US and
China have impacted Hong Kong as an IFC, and how the city has been coping. The analysis
highlights two main points. First, the punitive US actions against Hong Kong did have
some intended effects. But the financial sanctions and the other punitive measures did
not cause Hong Kong or Mainland officials to reverse course, to walkback the implemen­
tation of the NSL in Hong Kong. Second, the impact of the US pressure on Hong Kong as
an IFC was limited, at least for the immediate term. Not only was Hong Kong as IFC not
fundamentally damaged after the US punitive measures were applied; in fact,
Hong Kong’s financial market registered strong growth in 2020 and 2021 (though growth
waned in the latter half of 2021, largely due to national regulatory tightening). Large
 ASIA PACIFIC BUSINESS REVIEW 675

waves of money actually surged into Hong Kong’s financial market in 2020 and 2021 from
European, Asian and Mainland sources, and drove demand for PRC-based assets listed in
Hong Kong. Rather than banks in Hong Kong and the IFC being punished, these large
money flows acted as offsetting portfolio investment to the US divestment in the same
period, and buoyed Hong Kong’s capital markets.
The analysis above highlighted how these large money flows into Hong Kong were, in
part, the cumulative effect of the combination of US actions when US politicians followed
their financial sanctions and other punitive measures against Hong Kong in mid-2020 with
financial and investment bans on China-based companies in late-2020. The cocktail of
measures led to intended and unintended consequences, and particularly pertinent in
this study are the unintended outcomes. But the growth in Hong Kong’s financial market
in 2020 and 2021 also resulted from the strategic intervention of Hong Kong officials to
strengthen the resiliency of the IFC, and to shield the city from geopolitical crossfire. Local
officials intervened to bolster the city’s position after previous crises episodes in 1997–98,
2002–03, and 2008–09, and their intervention was crucial once again when the Biden
administration extended the Trump measures in June and July 2021, and Hong Kong
officials advocated successfully with central authorities to postpone the NPC SC vote on
the application of China’s new anti-sanctions law in Hong Kong. The Central-level decision
to suspend the vote helped Hong Kong to avoid being drawn further into the sanctions
crossfire, at least for a certain period. The irony is that Hong Kong’s recovery and return to
economic growth in 2020 and 2021 – and the resiliency and continuing growth of the
IFC – was also beneficial to US banks and US corporates that remain heavily invested in
Hong Kong. Despite the reprieve, geopolitical risk has continued to grow within the Asia-
Pacific region and outside the region, globally. Geopolitics has become the foremost
concern facing the city as an IFC and global business hub, and Hong Kong’s competitive
resilience will likely need to be demonstrated yet again.

Notes
1. By a dynamic IPE perspective, I mean a mode of social scientific analysis that examines the
inter-relations between politics and economics and the international and domestic realms to
comprehend social reality, and where the main goal of the analysis is to understand the
sources of systemic change, the potential for, and drivers of structural change.
2. I thank one of the anonymous reviewers for raising this point.
3. The main ‘limitations of the research’ is that, due to COVID-19 travel restrictions, the author
was not able to conduct in-person field research and data gathering for this paper, on the
macro or micro-dimension of the study, in Hong Kong, China and the US. The analysis has
relied mainly on textual analysis, and on data from the HKMA and the IMF. The author
believes the data is reliable.
4. Under the “special status” category of the United States, Hong Kong’s exports to the US
treated separately from the Mainland’s more managed economy,; Hong Kong had a zero tariff
on import of US goods; and the US allowed the US dollar to be “freely exchanged” against the
Hong Kong dollar.
5. Author’s notes on Paul Chan’s presentation to the Asia Pacific Foundation of Canada on
Hong Kong’s competitiveness as an International Financial Centre, May 11, 2021.
6. Author’s notes on Paul Chan’s presentation, May 11, 2021.
7. Another key factor was the US decision to only impose limited or measured financial
sanctions.
676 G. T. CHIN

8. TIAA is one of the leading retirement pension providers in the US for people in the education,
not-for-profit, healthcare and government fields.
9. EO 14032 created a new “Non Specially-Designated Nationals Chinese Military-Industrial
Complex Companies (NS-CMIC) List”, administered by the US Treasury Department’s Office
of Foreign Assets Control (OFAC). 59 entities were on the list as of October 25, 2021.

Acknowledgement
The interpretations and recommendations in this piece are solely the responsibility of the author.
Some sources for this study shall remain anonymous to maintain confidentiality. My thanks
especially to Tai-lok Lui the guest editor, journal editor Ingyu Oh, and Benjamin J. Cohen, Louis
Pauly and Vic Li for their detailed suggestions, Nicholas Kwan, former Director of Research at the
HKTDC for his personal comments, Rachael Bedlington, Mark Blyth, Esther Cheong, Gisuseppe
Gabusi, Daniel Koldyk, Alex Koustas, Robert Latham, Christopher McNally for their suggestions on
earlier drafts, and the journal’s two anonymous reviewers.

Disclosure statement
No potential conflict of interest was reported by the author(s).

Notes on contributor
Gregory T. Chin is an Associate Professor in the Department of Political Science, and Faculty of
Graduate Studies at York University (Canada). His research interests are in international and
comparative political economy with a focus on China, Asia, the BRICS, international money, finance,
and global governance. His research on China, the Asian region and world order started in the early
1990s, and spans four decades. His most recent projects are ‘US Financial Warfare on China’ (to be
published in Italian by Istituto Treccani, Visions Series), and ‘Canada Amid the US-China Trade War’
published in Canada Among Nations 2021. His report ‘EGG Commentary Series: The Evolution of the
New Development Bank (NDB) at Six and Beyond’ is posted online by Global Policy Journal.

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