Putting Your Money Where Your Mouth Is Not: China and Russia’s Implementation of Economic Sanctions

Abstract

How do China and Russia practically wield coercive economic power? Both states frequently employ unilateral sanctions. Simultaneously, they regularly communicate to domestic and international audiences that they vehemently oppose them. This duality typically limits their sanctions toolbox to trade restrictions that can be plausibly denied. Through what mechanisms can deniable sanctions be implemented, and what does this imply about the nature of target vulnerability to China and Russia’s sanctions? Sanctions scholarship focuses on Western sender states and assumes sanctions are announced publicly and introduced via transparent policy instruments. It gives only limited consideration to how authoritarian states introduce more discreet economic restrictions. Existing knowledge of how states implement deniable sanctions stems from single case studies and is undertheorized. This article seeks to address those gaps. Empirically, it introduces a new qualitative dataset of 103 sanctions episodes occurring between 2000 and 2023 (China: 53; Russia: 50) and uses it to put the two states’ approaches in comparative perspective. Theoretically, leveraging within- and cross-case comparisons of the implementation of almost 300 separate sanctions, it maps out six distinct mechanisms and their dynamics. In doing so, it presents a new account of China and Russia’s sanctioning behavior with implications for policy debates about countering their economic coercion.

Resumen

¿Cómo ejercen China y Rusia el poder económico coercitivo en la práctica? Ambos Estados emplean con frecuencia sanciones unilaterales. Al mismo tiempo, ambos Estados comunican periódicamente al público, tanto nacional como internacional, que se oponen vehementemente a ellas. Esta dualidad suele limitar sus herramientas de sanciones a restricciones comerciales que pueden denegarse de manera plausible. ¿A través de qué mecanismos se pueden implementar sanciones negables?, ¿qué implicaciones tiene esto sobre la naturaleza de la vulnerabilidad del país objetivo de las sanciones de China y Rusia? Los trabajos académicos en materia de sanciones se centran en los Estados emisores occidentales y asumen que las sanciones se anuncian públicamente y se introducen a través de instrumentos políticos transparentes y solo prestan una consideración limitada a las formas cómo los Estados autoritarios introducen restricciones económicas más discretas. El conocimiento existente en materia de cómo los Estados implementan sanciones negables proviene de estudios de casos individuales y existe poca teoría al respecto. Este artículo busca abordar esas brechas. De manera empírica, el artículo presenta un nuevo conjunto de datos cualitativos formado por 103 episodios de sanciones ocurridos entre 2000 y 2023 (53 de China y 50 de Rusia) y lo utiliza para poner los enfoques de ambos Estados en perspectiva comparativa. De manera teórica, aprovecha las comparaciones, dentro de cada caso y entre casos, de la implementación de casi 300 sanciones distintas, y traza seis mecanismos distintos con su dinámica correspondiente. Al hacer esto, el artículo presenta un nuevo relato del comportamiento sancionador de China y Rusia que tiene implicaciones para los debates en materia de políticas relativas a cómo contrarrestar su coerción económica.

Résumé

Comment la Chine et la Russie usent-elles de leur pouvoir de coercition économique en pratique? Ces deux États ont fréquemment recours à des sanctions unilatérales. Dans le même temps, ils communiquent souvent leur ferme opposition à celles-ci devant des publics nationaux et internationaux. Cette dualité limite normalement leurs possibilités en matière de sanctions aux seules restrictions commerciales que l'on peut refuser d'admettre de manière plausible. Quels sont les mécanismes qui permettent de mettre en œuvre des sanctions niables et quelles en sont les implications pour la nature de la vulnérabilité de la cible aux sanctions chinoises et russes? La recherche sur les sanctions se concentre sur les États émetteurs occidentaux et suppose que les sanctions sont annoncées publiquement et introduites par le biais d'instruments politiques transparents. Elle s'intéresse très peu à l'introduction discrète de restrictions économiques par les États autoritaires. Actuellement, ce que l'on sait de la mise en œuvre de sanctions niables par les États provient d’études de cas uniques et la théorisation est lacunaire. Cet article vise à pallier ces insuffisances. Sur le plan empirique, il introduit un nouvel ensemble de données qualitatif de 103 épisodes de sanctions intervenant entre 2000 et 2023 (Chine: 53; Russie: 50) et s'en sert pour comparer les approches des deux États. Sur le plan théorique, à partir de comparaisons entre et dans les cas de mise en œuvre de 300 sanctions distinctes, il représente six mécanismes distincts et leurs dynamiques. Ce faisant, il présente une nouvelle explication du comportement de la Chine et la Russie en matière de sanctions, qui s'accompagne d'implications pour les débats politiques sur la réponse à leur coercition économique.

Introduction

Alarm about economic coercion and its potential consequences for international security has reached fever pitch. Not since the 1973 oil embargo have so many Western states voiced mutual concern about vulnerability arising from economic interdependence with adversaries, nor so vigorously pursued novel policies to mitigate it. A flurry of initiatives–from the Group of Seven (G7)’s new “Coordination Platform on Economic Coercion” to the European Union’s 2023 “Anti-Coercion Instrument” to reports that the US State Department has created a dedicated team to advise allies on countering “trade coercion”–underscore the apparent urgency with which governments are moving to address the issue.¹ Tools are being designed with two main actors in mind: the People’s Republic of China and the Russian Federation. Yet, although a growing chorus of voices agrees more must be done to counter the threat of economic coercion posed by Beijing and Moscow (Hackenbroich and Zerka 2021; Dalder and Rasmussen 2022; Cha 2023), the precise nature of that threat is often underspecified. Exactly which industries are vulnerable to coercion, and through what mechanisms?

Answering these questions requires a detailed understanding of how China and Russia practically wield coercive economic power. However, despite a recent boom in research on Chinese economic statecraft (Norris 2016; Lai 2018; Wong 2021; Miura 2023) and a steady stream of scholarship on Russian economic coercion over the past two decades (Drezner 1997; Drezner 1999; Newnham 2011; Hedberg 2018), the political science literature on sanctions has overwhelmingly focused on the approaches of Western governments. As a consequence, while we know much about the sanctioning behavior of actors like the United States and European Union–including detailed accounts of the politics that shape their sanctions (Whang 2011; Jeong and Peksen 2019; Tama 2020; Meissner 2024) and how their restrictions are practically implemented and enforced (Early and Preble 2020; Preble and Early 2024; Giumelli et al. 2022)–similar knowledge about Beijing and Moscow remains fragmented. Addressing this is important. Any policy agenda for countering economic coercion should be tailored toward the practice of its targets, yet China and Russia do not sanction like the states that dominate sanctions research. Although both states possess legislative regimes for formal sanctioning, they use these relatively less frequently and instead tend to introduce trade restrictions in “informal” ways that allow officials to deny political motivations (see, e.g., Svoboda 2019; Lai 2021). This is arguably due to a shared and fundamental tension in their sanctioning policies: while they actively use unilateral sanctions, they also vehemently denounce them.²

Navigating that tension appears to have led China and Russia to engage in remarkably similar patterns of sanctioning behavior that remain surprisingly underappreciated. While some scholars note parallels between Beijing and Moscow’s sanctions (Morris et al. 2019; Drezner 2024, 10), they have not been the subject of focused comparative study. Both actors elude large-N research because their “unofficial” sanctions are seldom recorded in sanctions databases.³ While there is a nascent push to correct for that neglect (Whang and Paik 2023; Zhang and Shanks 2024), most empirical work employs case studies of specific issue areas—such as Russia’s use of the “energy weapon” (see, e.g., Stegen 2011) and China’s tourism boycotts (see, e.g., Paik 2020)—or discrete episodes (see, e.g., Svoboda 2019; Gholz and Hughes 2021). Moreover, while it is recognized that how sanctions are implemented conditions industry vulnerability (see, e.g., Lim and Ferguson 2022), few studies distinguish variation in implementation mechanisms.⁴ As a result, we not only lack a general comparison of China and Russia’s approaches but also a macro perspective on patterns in when and how they use sanctions differentially over time.

This article seeks to fill those gaps. Following the approach of comparative studies of China and Russia’s statecraft in other issue domains (Howells and Henry 2021), it builds on research from the relatively more studied case of China’s sanctions to develop an analytical framework for analyzing the implementation of sanctions by both states. That framework anchors a structured, focused comparison, which draws upon a new dataset documenting the implementation of almost 300 separate sanctions by China and Russia across 103 episodes between 2000 and 2023, presented in a supplementary empirical appendix designed in accordance with current best practices regarding analytic transparency and data access in qualitative research (Kapiszewski and Karcher 2021a; Gaikwad and Herrera 2023). I seek to achieve two research objectives. First, to map out and make descriptive inferences about the mechanisms through which both countries implement sanctions. Second, by conducting within- and cross-case comparisons, to identify patterns that have heuristic value for refining existing theories of informal sanctions by inductively identifying new mechanisms, scope conditions, and hypotheses about their use (George and Bennett 2005).

I present several important findings. First, although both states have begun implementing sanctions via formal legislation with increased frequency in recent years, they have only done so reactively and under narrow circumstances. In particular, they only appear to sanction formally when they can plausibly claim to be taking “countermeasures” against the wrongful acts of other states—most notably, and ironically, the imposition of sanctions on their own economies. Second, in the more common case where that path is not open to them, both states draw on a similar toolbox for implementing sanctions informally, dominated by four main mechanisms: disrupting trade with legal rules that serve regulatory functions unrelated to sanctioning (conversion), drawing out or obstructing official procedures necessary for economic exchange to occur (bureaucratic obstruction), informally directing domestic firms to cease specific transactions (blacklisting), and discouraging domestic consumers from purchasing target products (boycott fomentation). I outline why those mechanisms are not equally available and how they pose different levels of risk to different product categories. Finally, the paper provides evidence congruent with claims that Beijing and Moscow care deeply about avoiding the appearance of wanton unilateral sanction use—in most cases, officials are identified offering some explanation as to why a restriction is not a sanction or is justified under international law. Below, I suggest several ways policymakers might use this curious hangup to their advantage when crafting emerging frameworks for countering economic coercion.

The article makes several contributions. For political scientists concerned with the implementation and enforcement of sanctions, it offers the first focused study of China and Russia. Prominent sanctions scholars have recently lamented that “how governments implement economic sanctions has only barely been explored” (Early and Cilizoglu 2020, 441), and the “dearth of data on non-Western sanctions initiated by China and other countries” (Peksen 2019, 644). Existing studies overwhelmingly concentrate on democracies. My analysis offers a new perspective, illuminating the practice of the most prominent nondemocratic sanctioners with more than eighty new cases that are not included in the major sanctions datasets. For those interested in the relationship between law and economic power, I extend earlier research on how the structure of international and domestic legal rules may shape the way that states approach sanctioning (Ferguson 2022; Kim, Perlman, and Zeng 2024). A third contribution is to the economic statecraft literature. Scholars have pushed for the field to adopt a more comparative approach (Reilly 2021, ch. 7), and this paper offers a template for moving that agenda forward by considering how institutional differences between states may shape their approach.

The second section reviews the literature on the implementation of sanctions and China and Russia’s economic statecraft. The third section develops an analytical framework for studying the introduction of traditional and informal sanctions, specifying five mechanisms of implementation and their dynamics. The fourth section compares China and Russia’s approaches between 2000 and 2023. The final section leverages the empirical analysis heuristically to refine and expand the mechanisms in the analytical framework before considering the policy implications arising from the analysis and outlining suggestions for future research.

Economic Sanctions and Their Implementation

Unilateral economic sanctions are government-directed measures that limit or end different forms of economic exchange between the imposer of the sanction (the “sender”) and another state (the “target”). Sanctions may be motivated by a variety of goals.⁵ However, this paper focuses on sanctions designed to impose costs in order to apply coercive pressure during political disputes. While early scholarship was concerned with “whether” sanctions work, the thrust in recent decades has been toward examining “when” (i.e., under what conditions) they are effective (Peksen 2019).

By design, the imposition of sanctions causes disruption for economic actors within the target. Importantly, however, it also does so for those within the sender state. Such disruption may not be welcomed by private firms and individuals—the actors responsible for most contemporary international exchange—if they prioritize profit over supporting their government to achieve its political objectives (Bapat and Kwon 2015). This may lead economic actors to circumvent restrictions and undermine their intended effects. For sanctions to be effective, governments must therefore possess appropriate policy tools for implementing restrictions and enforcing compliance.

Extant research on implementation focuses on democracies like the United States and the European Union (Early and Preble 2020; Early and Peterson 2021; Giumelli et al. 2022) and assumes that the sanctioning process begins when states “create laws to disrupt the trade between their national firms and target countries” and task officials with “enforcing these laws” (Morgan and Bapat 2003, 79). In the United States, for example, sanctions are introduced in legislation or presidential executive orders before implementation is delegated to different sections of the bureaucracy, notably the Treasury Department’s Office of Foreign Assets Control. This is the most straightforward approach to implementation when governments are using “formal” sanctions that they openly announce.

In contrast, China and Russia’s approaches have received limited attention in the sanctions literature. Few of their actions are recorded in the five “major” datasets (Portela and Charron 2023) used for large-N research (see Table 1).⁶ Instead, most research has been produced by area studies scholars focused on economic statecraft. Studies of China’s economic statecraft have been particularly prominent (Norris 2016; Reilly 2021; Wong 2021). Reilly was one of the first to draw attention to the fact that China “rarely openly declares its economic sanctions” (2012, 123) and examine episodes in which they had been used. Detailed case study work now documents China’s sanctions against Norway (Chen and Garcia 2016), Japan (Gholz and Hughes 2021), South Korea (Miura 2023), Taiwan (Lai 2021), and Australia (Ferguson, Waldron, and Lim 2023). Some researchers have also attempted comparative studies of small sets of cases (Lai 2018; Kwon 2020). However, studies seldom give explicit attention to implementation. The few efforts to typologize China’s strategies for implementing sanctions have been limited to specific forms of exchange (such as on tourism: Lim, Ferguson, and Bishop 2020) or actions in specific cases (such as against South Korea: Lim and Ferguson 2022).

Moscow’s sanctions have received similarly fragmented attention. Noting the absence of studies on Russia, Drezner examines numerous cases of Russian economic coercion during the 1990s and notes that—like China’s recent approach—the linkage between sanctions and political disputes was often “only implied” (1997, 84; 1999, 153). That tendency continued into the 2000s, as documented in numerous studies of Russia’s manipulation of gas and oil exports to influence neighboring countries (Stegen 2011; Blank and Kim 2016) and in case studies of campaigns against Georgia (Newnham 2015), Ukraine (Svoboda 2019), and the United States and European Union (Hedberg 2018). Yet no research has devoted focused attention to the issue of sanctions implementation, nor what variation in it across cases might suggest about the dynamics that constrain or enable Moscow’s ability to employ economic power.

Reflecting this limited treatment, prominent sanctions scholars have recently highlighted the need for more “descriptive knowledge about and comparative analyses of how governments implement sanctions” in different countries around the world (Bapat et al. 2020, 453). There are compelling reasons to study China and Russia’s approaches to implementation jointly. They are the largest nondemocratic economies and share common bureaucratic and political economy legacies from their transitions from state socialism to market-based systems (Rochlitz et al. 2015). More importantly, they are often jointly cited as the exemplars of a novel style of “informal” sanctioning that is undertheorized. As this paper extensively details, formal unilateral sanctions—which are publicly acknowledged and written into official laws—have not represented Beijing and Moscow’s standard approach.¹² Instead, in more than 80 percent of cases between 2000 and 2023, officials denied that economic disruption was politically motivated or represented a sanction. The need to maintain a façade of “deniability” for such restrictions suggests China and Russia may face similar constraints when implementing sanctions. Yet, despite several researchers noting these parallels (Morris et al. 2019; Brandt and Cooper 2022; Drezner 2024), no systematic comparative studies exist. This represents an empirical gap in the literature on sanctions implementation and a missed opportunity to further theorize informal sanctions as instruments of state power.

Implementing Informal Economic Sanctions

This section develops a framework for analyzing China and Russia’s approaches to sanctions implementation. It begins from the observation that state preferences about how transparently to conduct market interventions will vary. Formal sanctions, which are defined as measures that restrict economic exchange that are openly acknowledged as sanctions and imposed under official laws that provide explicit legal foundations for sanctioning, are inherently public. Yet, the imposition of sanctions, like military maneuvers (Carson and Yarhi-Milo 2017) and regime change operations (Poznansky 2020), is a strategic activity that states may wish to conceal or deny. While engaging in deniable statecraft poses trade-offs, several factors may motivate a preference for sanctioning this way.¹³ For states that have criticized the use of unilateral sanctions by Western powers, sanctioning discreetly may minimize charges of hypocrisy (Ferguson 2022). It may also enable states to avoid other reputational costs of violating international rules that prohibit discriminatory trade restrictions (Downs and Jones 2002). Finally, under certain conditions, ambiguity may also generate strategic benefits, such as complicating the ability of a target to respond effectively (Green et al. 2017, 32) or giving the sender greater flexibility to wind back restrictions without facing domestic blowback.¹⁴

Maintaining deniability poses a unique constraint on sanctions implementation by requiring officials to offer some alternative explanation for disruption to economic exchange. Governments seeking to obscure their participation in covert military operations are known to have dressed troops up in foreign uniforms (Carson 2016, 124). How can states “dress up” their implementation of economic sanctions? Synthesizing insights from existing scholarship on China’s sanctions, this section specifies and details four common mechanisms and the distinct dynamics that plausibly shape when they are used and the impacts they generate.

The first mechanism involves government officials leveraging their influence over procedures necessary for economic exchange to occur. Here, officials do not explicitly state exchange cannot occur, but rather draw out or otherwise obstruct bureaucratic requirements. The most common example cited in existing research is a customs “go-slow,” where goods are subjected to lengthy inspections, causing delays (see, e.g., Chen and Garcia 2016).¹⁵ However, there are many other government processes indispensable for modern commerce to occur, such as the issuance of certificates and licenses and the conclusion of new international agreements. Provided officials have influence over a necessary procedure and can offer some superficial explanation for delay or omitting to perform certain functions, this mechanism affords scope to implement deniable sanctions. Importantly, this is done without making specific findings or determinations, which distinguishes it from the second mechanism, which hinges on the actual application of legal rules. I label this Bureaucratic Obstruction.

The second option is for officials to disrupt trade by strategically applying legal rules that serve regulatory functions unrelated to sanctioning. Economic exchange is governed by a wide range of technical rules, both at and behind a state’s borders, and these may be “converted” for the purpose of imposing costs on targets (Drezner 2024, 10). For example, officials might cite the detection of pests in shipments and impose a temporary ban on the grounds that trade poses a phytosanitary risk (Svoboda 2021). This mechanism differs from bureaucratic obstruction insofar as it requires those officials to make a formal determination and offer some evidence of a violation of existing rules. While this may mean the restriction is more decisive, it may also make it easier for affected actors to dispute.¹⁶ Existing research posits conversion will be most likely where rules afford officials wide interpretive discretion.¹⁷ I label this Conversion.

The third mechanism, which is labeled Blacklisting, involves outsourcing implementation to private or state-owned firms by unofficially directing them to cease economic exchange with target state actors (Lim and Ferguson 2022). If firms comply and publicly claim that the decision was made independently, governments may successfully generate disruption while maintaining scope to deny being behind the restrictions. Importantly, no laws formally require firms to comply with the instructions. Compliance may be sought via the issue of threats or promises. While this form of implementation has been observed in several case studies,¹⁸ scholars have not specified hypotheses about its use other than to note its availability likely depends on whether governments are able to exercise control over market actors discreetly.¹⁹

The final mechanism, Boycott Fomentation, outsources implementation directly to consumers. Here, government officials may take steps to “foment” boycotts such that economic actors autonomously limit their consumption of goods or services from a target state. Fomentation is often conducted via state media, but selective messaging that discourages certain consumption might also be done by individual officials or government agencies. Notably, economic exchange is not banned, and consumers retain the option to purchase as they please. As such, while boycotts may cause significant disruption to economic exchange, governments may deny any sanction by blaming irregularities on the independent actions taken by patriotic consumers (Reilly 2012). Researchers expect boycott fomentation to be most viable where governments possess “informational tools to whip up patriotic sentiments,” and during political disputes that involve salient historical and identity issues (Wong, Easley, and Tang 2023, 11).

While not necessarily theoretically exhaustive,²⁰ these four mechanisms can be used to begin categorizing the different measures documented in the appendix, and to structure the analysis of China and Russia’s approaches. Together with the formal alternative, they are summarized in Table 2.

Comparing China and Russia’s Approaches

The Appendix. Existing studies of China and Russia’s use of sanctions overwhelmingly concentrate on one or a small number of cases. While helpful for developing an understanding of the basic mechanisms through which their sanctions are introduced, it provides limited leverage for probing the conditions under which they are differentially employed. Moreover, China and Russia’s sanctions are poorly represented in existing databases. One reason for this is that their sanctions are often ambiguous and contested, such that identifying cases requires more analytical work than simply citing the “laws on the books” (Bapat et al. 2020, 455).

A new empirical resource is needed. However, identifying and describing 103 separate cases, while also satisfying the demands of analytic transparency and data accessibility (see Gaikwad and Herrera 2023), cannot be done within the constraints of a single article.²¹ As such, they are presented in an online empirical appendix, which documents observations about when, how, and why sanctions appeared to be imposed in each case and is annotated consistent with the logic of Annotation for Transparent Inquiry (Kapiszewski and Karcher 2021b) to explain coding decisions, elaborate on technical detail, and clarify why specific inferences are made. Given my research objectives, I narrow my focus to the implementation stage of the sanctioning process and document three main observations for each case: the apparent trigger, the mechanism(s) of implementation and affected exchange, and the official explanation for disruption. Due to that focus, and because of methodological challenges in coding outcomes when there is no stated sender objective in more than 80 percent of cases, I do not evaluate sanctions outcomes.²² The appendix utilizes more than 600 primary and secondary sources to document almost 300 separate sanctions. Recognizing some readers may not wish to engage with an appendix with more than 800 footnotes, I present the most salient detail here and employ a simple cross-referencing system that allows interested readers to quickly find relevant detail if they wish to.

Methodology. The analyses follow the logic of “structured, focused comparison” (George and Bennett 2005, ch. 3). They are structured in that they are guided by the same questions and focused as they are anchored around the analytical framework developed in the previous section, which narrows attention on mechanisms of implementation. The purpose is not to develop a new general theory or test specific hypotheses. Rather, by conducting a disciplined analysis of the two sets of cases through the lens of that framework, I seek to make descriptive inferences about Beijing and Moscow’s approach and refine existing theories of their sanctions by inductively identifying new scope conditions, variables, hypotheses, and mechanisms.²³

China

Formal Sanctions. China is a longstanding and vocal critic of economic sanctions. Researchers attribute this to Beijing’s own experience as a target of international sanctions (Nephew 2019) and its long-standing advocacy for the principle of “nonintervention” in the internal affairs of sovereign states (Cai 2021). Though opposition initially extended to all sanctions, China gradually softened its position on multilateral sanctions authorized by the United Nations Security Council (UNSC). Beginning in 2006, China ceased its past practice of abstaining and occasionally voted for and implemented restrictions against North Korea and Iran. Opposition to sanctions not authorized by the UN, however, persisted. Among other proclamations, twice annually since the early 1990s, China has jointly introduced resolutions to the UN General Assembly denouncing “unilateral coercive economic measures” (Hofer 2017; Yu 2021). Such opposition may partially explain China’s reluctance to publicly acknowledge its own sanctions (Xiong 2024). Nevertheless, formal unilateral sanctions have been introduced in several cases in recent years, and China has begun to develop new legal tools for implementing them.

The appendix identifies twenty-five formal sanctions (see Figure 1). Only two cases involved trade sanctions (restrictions on trade in specific goods or services), which were introduced against the United States during the trade war (Appendix 2.32) and Taiwan via the suspension of permits for individual travel in 2019 (Appendix 2.34). Other cases involved targeted sanctions against specific individuals or entities. The specific restrictions were not always announced by officials, but typically included a travel ban and restrictions on “doing business” in or with China.²⁴

Some ambiguity surrounds the laws through which these sanctions were implemented. Announcements regarding targeted sanctions did not specify the law under which they were introduced, simply noting they were done in “accordance with relevant laws” (see, e.g., Appendix 2.47). China has developed several new laws for the purpose of implementing formal sanctions in recent years (Webster 2022); however, these were only utilized in two cases in the period under analysis (in response to US sanctions in December 2022 and April 2023, respectively, Appendix 2.49 and 2.51). These sanctions were introduced under the 2021 Anti-Foreign Sanctions Law, which provides a foundation for introducing sanctions against foreign entities or individuals in a wide range of circumstances.

When does China choose to sanction formally? Patterns across the cases point to two circumstances. First, in retaliation against the imposition of sanctions or other trade restrictions on China.²⁵ Second, in response to perceived support for “Taiwanese independence.”²⁶ In both situations, Chinese officials explicitly framed their sanctions as countermeasures against illegal actions of the target state or actors.

Bureaucratic Obstruction. Sanctions were implemented via bureaucratic obstruction thirty-three times across eighteen cases, making it the second most common informal mechanism. It was predominantly used to restrict imports. In at least one case featuring Mongolia in 2002, border crossings were physically closed by Chinese officials for “technical reasons” (Appendix 2.2), but most cases involved delays caused by stepped-up customs inspections by China’s General Administration of Quality Supervision, Inspection, and Quarantine (AQSIQ). There was no particular pattern in the types of products targeted—ranging from perishable goods like Norwegian salmon (stringent sanitary and veterinary testing: Appendix 2.11) to manufactures like American automobiles (individual components checked for compliance with emissions standards: Appendix 2.32) and minerals like Australian coal (lengthy environmental testing: Appendix 2.35). The only instance where exports were targeted was during a 2010 dispute with Japan, where the processing of rare earth element (REE) shipments was apparently slowed (Appendix 2.11).

Beyond these “go slows,” officials also delayed other administrative functions necessary for exchange during several disputes. Prominent examples include extensive delays faced by South Korean video game developers waiting for product licenses during the THAAD dispute (Appendix 2.25) and the State Administration for Market Regulation’s delaying approval of a merger between US chipmaker Qualcomm and rival NXP, causing the deal to collapse (Appendix 2.32). In several cases, evidence suggests Chinese officials delayed concluding international agreements that would have expanded market access for target states,²⁷ or providing anticipated finance, such as a loan that had been under negotiation between China and Mongolia prior to Ulaanbaatar receiving the Dalai Lama in 2016 (Appendix 2.23).

One trend emerging from cases that took place over longer periods of time is that bureaucratic obstruction was often employed earlier in disputes and subsequently substituted with more concrete measures (such as bans on specific imports via conversion in the 2020 dispute with Australia: Appendix 2.40, or formal sanctions in the US trade war: Appendix 2.32).

Conversion. Sanctions were implemented via conversion sixty times (38 percent) across nineteen cases, making it China’s most common mechanism. Its use can be disaggregated according to the underlying legal rules applied. At least twenty-one sanctions involved what can broadly be characterized as technical barriers to trade (TBT), which include technical regulations and standards that specify requirements for products relating to factors including labeling, packaging, design, and performance, as well as certification and import/export licensing. Such rules were mostly used to restrict processed agricultural goods, such as milk powder (Appendix 2.24), food products (Appendix 2.25, 2.34, and 2.48), and beer (Appendix 2.40). In a few examples, they were also used to restrict manufactured goods²⁸ and the export of minerals.²⁹ Perishable meat products were also restricted due to issues with labeling and other “documentation.”³⁰ A second set of twenty-three sanctions involved the use of sanitary and phytosanitary (SPS) rules, which are designed to protect human, animal and plant health from pests and diseases. Such rules were overwhelmingly used to disrupt perishable agricultural products, such as Norwegian salmon (Appendix 2.12), Taiwanese pineapples (Appendix 2.39), and Canadian canola (Appendix 2.36).

A third form relied on anti-dumping and countervailing duty (AD/CVD) rules. In four cases, the Ministry of Commerce (MOFCOM)'s decision to launch new AD/CVD investigations during disputes was interpreted as a sanction,³¹ as was the imposition of such duties in three cases.³² Compared to the first three categories of rules, which are applied at the border and governed by specific international legal regimes,³³ the fourth category regulates economic activity behind the border. In at least one case, Chinese officials appeared to selectively use domestic antitrust rules to apply pressure on American companies (Appendix 2.17). In other cases, the mix of laws was wider. The experience of South Korean firms in Case 2.25 is revealing, where some companies were subjected to tax investigations, several factories and nearly all of conglomerate Lotte’s Lottemart stores were forcibly closed for violating occupational health and safety rules, and electric vehicle manufacturers using South Korean batteries were excluded from subsidies. The number of cases where domestic laws have been converted may be small because the scope for use is limited by the need for target firms to operate within China.

Blacklists. Blacklists were documented twenty-three times. This mechanism appeared to underpin several cases where state-owned China National Petroleum Corporation (CNPC) restricted oil exports to North Korea.³⁴ REE traders were reportedly instructed to cease exports to Japan in 2010 (Appendix 2.11), and blacklists were also apparently used to restrict the export of certain inputs to Lithuania in 2021.³⁵ More common, however, were blacklists restricting different types of imports. Chinese tourism operators were instructed to reduce or cease offering outbound travel services in at least six cases, affecting states including France, Taiwan, and Palau (Appendix 2.8, 2.21, and 2.26). Importers were also directed to cease purchasing coal, copper, and cotton during a dispute with Australia (Appendix 2.37), while state-owned airlines were apparently directed to delay aircraft orders during disputes with Germany and France (Appendix 2.6 and 2.9).

A theme emerging from the cases is that blacklists are typically only issued to domestic (Chinese) industries dominated by a small number of firms. Outbound tourism, the import of oil, coal, cotton, and aircraft, and the export of REEs are all concentrated sectors with a relatively small number of (often state-owned) economic actors. There are very few cases where directions were issued to industries in which large numbers of firms participate.³⁶ In one case where this occurred—when importers received text messages instructing them not to import Australian wine and lobster (Appendix 2.37)—the blacklist was quickly replaced by other restrictions, plausibly due to compliance issues.

Boycott fomentation. Boycott fomentation was the least common form of implementation, occurring in thirteen cases.³⁷ The most prominent examples, where a wide variety of consumer goods and target companies with operations within China were affected, were during disputes with Japan (Appendix 2.15) and South Korea (Appendix 2.25). In those cases, and during disputes with France (Appendix 2.8) and Sweden (Appendix 2.45), boycotts were encouraged in state media and largely tolerated by Chinese authorities.³⁸ Boycotts otherwise only targeted outbound tourism. In most cases, these were encouraged indirectly, typically via the issue of travel warnings by the China National Tourism Association or embassy officials.³⁹ China’s sanctions over time are summarized in Figure 2.

Russia

Formal. Like China, the Russian Federation (and the Soviet Union before it) has historically been a staunch opponent of unilateral sanctions. Scholars argue this stems from Moscow’s experience as the target of various sanctions regimes during the Cold War (Doraev 2015) and have detailed how its opposition is reflected in frequent statements and support for United Nations General Assembly resolutions condemning “unilateral coercive measures” (Hofer 2017). Despite this, Russia began taking steps to enforce UNSC-authorized multilateral sanctions earlier than China. An ongoing legislative basis for sanctions was introduced in 2006,⁴⁰ and this underpinned the imposition of formal sanctions in several cases, notably in response to Western sanctions imposed following Russia’s annexation of Crimea in 2014.⁴¹ A 2018 law also authorized the use of countermeasures against foreign legal entities or individuals in states that impose sanctions on Russia.⁴² That law underpinned targeted sanctions against Ukrainian officials in 2018 (Appendix 3.39). Other targeted sanctions were imposed via specific decrees.⁴³ The 2006 and 2018 laws give the president power to authorize sanctions and task implementation to the executive arm of government, which then delegates enforcement to agencies under the Ministries of Foreign Affairs, Economic Development, and Industry and Trade, with the Ministry of Finance coordinating interdepartmental cooperation (Timofeev 2021).

Formal sanctions were identified in nine cases and implemented twenty-four times (see Figure 3). Trade sanctions only restricted imports, while targeted sanctions involved travel restrictions and asset freezes. They were almost always introduced as retaliation against the imposition of sanctions on Russia by other actors and framed as “retorsions” against violations of international law.⁴⁴ In one exception, Moscow sanctioned Turkey after a Russian jet was shot down on the Turkey–Syria border in 2015 (Appendix 3.34). In most cases, formal sanctions came after earlier sanctions were implemented informally.

Bureaucratic Obstruction. Russian officials utilized bureaucratic obstruction less frequently than their Chinese counterparts, with fifteen instances documented.⁴⁵ In five cases, officials from either Rospotrebnadzor (the Federal Service for Surveillance on Consumer Rights Protection and Human Wellbeing) or Rosselkhoznadzor (the Federal Service for Veterinary and Phytosanitary Surveillance) subjected imports to lengthy inspections at customs checkpoints, causing delays.⁴⁶ These “go slows” were later substituted with import bans on specific products via conversion.

Mirroring China’s closure of the border crossing with Mongolia (Appendix 2.2), officials closed the crossing with Georgia in 2006, citing the need for “reconstruction” (Appendix 3.7), and prevented trucks from using a bridge into Estonia in 2007, claiming it was in a “bad state of repair” (Appendix 3.10). Other illustrative examples include Russian officials refusing to issue tax labels for Moldovan wine exporters (Appendix 3.6) and visas to Georgian workers (Appendix 3.7) and delaying an agreement for visa-free travel with Georgia (Appendix 3.40).

Conversion. Conversion was Russia’s most common mechanism, utilized seventy-six (56 percent) times in thirty-three cases. Most frequently, the agencies responsible for quarantine, testing, and customs inspection—Rospotrebnadzor and Rosselkhoznadzor—cited SPS concerns to justify bans on primary goods. The detection of issues such as pests, impurities, and pesticides led to bans on perishables including meats (e.g., Polish pork: Appendix 3.5), fruits, and vegetables (e.g., Moldovan plums: Appendix 3.35), Turkish pepper (Appendix 3.34), and even Dutch flowers (Appendix 3.33). Processed goods were also cited for concerns about issues such as dangerous additives and forged veterinary certificates, including alcoholic beverages (e.g., Georgian wine: Appendix 3.7), smoked sprats (Appendix 3.20), and Ukrainian confectionary (Appendix 3.15). Several cases also saw restrictions introduced on TBT grounds, typically related to the labeling and packaging of processed goods such as canned vegetables and fruits (see, e.g., Appendix 3.18) or bottled beer (Appendix 3.24). Only one case affected manufactured goods: railcars from Ukraine that were said to violate technical regulations regarding steel casting (Appendix 3.15).

There were no allegations Russia converted anti-dumping investigations.⁴⁷ Russian authorities have, however, appeared to operationalize a wide range of domestic laws, including ones related to tax (Appendix 3.7), health and safety (see, e.g., Appendix 3.29), migration, residency and employment (Appendix 3.7), and aviation (Appendix 3.40). In many ways mirroring the experience of South Korea’s Lotte in China in Case 2.25, two highly visible US retail chains—McDonald’s and Burger King—were singled out for punishment in retaliation for Washington’s escalating sanctions on Moscow. In 2014, McDonald’s stores faced sudden inspections for issues ranging from sanitary standards (leading to the closure of at least twelve stores) to the sale of illegal toys and even allegations of money laundering (Appendix 3.23). Likewise, in 2015 Burger King had several stores closed and faced large fines for alleged issues with “ventilation systems, disinfection, insect control, layout of premises and unsatisfactory sanitary conditions of production areas, storerooms and utilities” (Appendix 3.31).⁴⁸

The Russian cases illustrate two additional categories of laws that can be converted. First, in two disputes, officials cited provisions in bilateral or regional free trade agreements (FTAs) to withdraw tariff preferences to target countries. In Case 3.17, a 1994 FTA with Georgia was suspended after Georgia signed an FTA with the European Union, and in Case 3.18, Russia suspended tariff-free treatment for nineteen categories of Moldovan exports, citing violation of an obscure rule in an annex to the Commonwealth of Independent States FTA. The second category involves contract provisions. In several cases, Russian firms cited alleged contract violations by target states in order to justify export restrictions (see, e.g., Appendix 3.1, 3.44).

Blacklists. Russian officials informally directed firms to cease exchange with target states fifteen times. In most cases, authorities appear to have directed energy companies to limit or stop the supply of gas or oil to target states. With the exception of Case 3.1 (where gas supplies to Georgia were cut by Inertgazstroi in 2000), the firms involved were state-owned—Gazprom for gas and Transneft for oil—and explained disruption as a consequence of commercial issues (such as contract violations: see, e.g., Appendix 3.44) or unspecified “technical” issues (see, e.g., Appendix 3.11). In one case, state-owned Russian Railways was apparently instructed to limit the carriage of cargo to Latvian ports (Appendix 3.37). In contrast with China, there was only one instance involving tour agencies (Appendix 3.38). One potential explanation for this is that Russia’s outbound tourism industry is more fragmented than China’s,⁴⁹ which may have made issuing and enforcing instructions difficult. Directions were only issued to a large number of private firms in one case, when traders were “ordered by the Kremlin” to halve shipments of oil products, metals, and coal via Estonia in 2007 (Appendix 3.10). This is consistent with the observation from China’s approach that blacklisting is less likely to be directed at industries in which many economic actors participate.

Boycott Fomentation. Boycott fomentation was least common, occurring four times. Fomentation contributed to two broad consumer boycotts during disputes with Georgia (Appendix 3.7) and Estonia (Appendix 3.10), cases that occurred over long periods of time and involved other economic disruption. Boycotts were explicitly promoted in the media and by government officials. In 2007, for example, Deputy Prime Minister Sergei Ivanov appealed, “Don’t buy Estonian goods. Don’t go to Estonia on vacation.” Retaliatory travel warnings were also issued, with two cases involving Turkey and Montenegro (Appendix 3.34 and 3.38).

Sabotage. Finally, the Russian cases highlight a possible fifth mechanism: sabotage of physical infrastructure. In at least two cases, Moscow plausibly orchestrated incidents that caused physical damage to gas (Appendix 3.7) and oil (Appendix 3.9) pipelines, in addition to an electricity transmission line (Appendix 3.7). In the first case, during a dispute with Georgia in 2006, Moscow blamed Chechen separatists for the incidents. The second, during a dispute with Lithuania, was blamed on an “accident.” This mechanism is considered in greater detail in the fifth section. Russia’s sanctions over time are summarized in Figure 4.

Comparison

How do China and Russia’s approaches compare, and what do any patterns suggest about the types of industries or products that are more or less vulnerable to coercive economic pressure during political disputes? At a macro level, there are several notable similarities. Both employed sanctions a similar number of times over the period of analysis, with increased frequency throughout the 2010s. Both also utilized them to restrict imports from target states more often than exports to them.⁵⁰ Officials in Moscow and Beijing also demonstrated a similar propensity toward introducing sanctions in ways that provided them some degree of deniability. Other similarities, and several distinctions, emerge in the specific mechanisms.

Formal. China and Russia appeared similarly reticent to publicly announce restrictions and implement them through official laws (see Figure 5). Surveying the “trigger” observations for formal sanction cases, the apparent exception to this is where restrictions could be framed as retaliation against the actions of other states in accordance with international law—most often in response to the imposition of sanctions that had not been authorized by the UNSC, but also to alleged interference in China’s “internal affairs” (regarding, for example, Taiwan), hostile military activities (such as Turkey’s shooting down of a Russian jet), or discriminatory trade measures by other countries.⁵¹ Their formal sanctions have therefore always been reactive. The countries began using formal sanctions only in the latter half of the period under analysis (2018 and 2014, respectively), with a recent trend toward increased use. Notably, Chinese officials have introduced targeted sanctions against specific individuals and entities more frequently (nineteen times) than trade restrictions (six times). Conversely, Russia has focused more on trade restrictions (sixteen times), with only eight targeted sanctions.

Bureaucratic Obstruction. Chinese and Russian officials implemented bureaucratic obstruction similarly, including through customs “go slows,” omissions to perform administrative functions, and the delayed conclusion of international agreements. However, this mechanism was used more frequently—and against a wider range of economic exchange—by China.⁵² Bureaucratic obstruction at customs tended to occur earlier in disputes, which may indicate officials endeavoring to detect genuine (if minor) violations before substituting the mechanism with stronger restrictions via conversion. In almost every Russian case with “go slows,” bans were subsequently introduced for alleged SPS or TBT violations. This was not true for China, with AQSIQ appearing to take a more cautious approach—perhaps explaining why some of Russia’s sanctions have been successfully challenged at the WTO, while none of China’s have.⁵³ That this mechanism was often used shortly after the initial trigger of the underlying disputes suggests that it can be operationalized relatively quickly, which may be one advantage, especially if the primary objective of the sanction is to signal. On the other hand, the longer bureaucratic obstruction occurs without a convincing rationale, the less plausible denials become. This may explain why the mechanism is often replaced with others during longer disputes and could be a disadvantage if the sanction is less motivated by signaling and more about imposing substantial and ongoing costs on the target.

Conversion. The strategic application of regulatory rules dominated both states’ implementation. Russia was particularly skewed toward this mechanism—representing 76 (57 percent) of its total 134 sanctions.⁵⁴ Officials at Rospotrebnadzor and Rosselkhoznadzor most frequently introduced bans on SPS grounds regarding food safety, plant health, or animal health and veterinary controls (see Figure 6). Both Russia’s and China’s use of SPS restrictions overwhelmingly affected perishable agricultural products, although they were also applied to some processed food products by Russia. Many argue the SPS agreement provides wide interpretive discretion for governments to introduce arbitrary restrictions.⁵⁵ That it was converted frequently is congruent with expectations about conditions under which conversion is viable.

Chinese officials from AQSIQ used TBT restrictions (regarding issues like labeling and certification) most frequently. TBT issues were most likely to affect processed and packaged goods, including food products and manufactured goods. Why might Russia have employed conversion more often? One possible explanation lies in different domestic institutional structures for enforcement, such as most at-the-border enforcement being tasked to two agencies in Russia and just one in China. Two agencies operating simultaneously may be able to cover more ground to detect potential violations, or indeed decentralization may promote a competitive dynamic between Rospotrebnadzor and Rosselkhoznadzor as they are housed in different government departments.⁵⁶ Another possibility is that officials in China are simply more cautious about (paper) compliance with WTO rules. Trade and other international law may influence decision-making where it penetrates organizational processes of foreign policymaking (Nuñez-Mietz 2016), and scholars have documented how—as part of China’s rise within the WTO system—state-led capacity-building efforts saw WTO law become a central concern of core government departments like MOFCOM.⁵⁷

As for behind-the-border, both states also used other domestic laws to disrupt the activities of target state firms operating within their jurisdiction, with the most notable cases affecting highly visible and public-facing companies, such as Lotte from South Korea (Appendix 2.25) and McDonald’s from the United States (Appendix 3.23). Only China appears to have employed AD/CVD rules, possibly reflecting its greater proficiency with the anti-dumping regime. The fact that the regime appears susceptible to conversion is also consistent with existing expectations about the mechanism, as the AD/CVD rules are often criticized for being excessively flexible. Finally, a novel Russian action involved the use of provisions in FTAs to justify restrictions.

Plausible advantages of this mechanism include greater control over enforcement (as it is carried out directly by government officials, rather than indirectly via firms or consumers) and that, once introduced, deniable restrictions can be kept in place to impose costs over extended periods of time without officials having to continue offering excuses (unlike bureaucratic obstructions).⁵⁸ The requirement for plausible jurisdiction over the relevant exchange, however, is the most apparent disadvantage of this mechanism.

Blacklists. Chinese officials directed economic actors to cease transactions more frequently than Russian officials. Moscow’s use of blacklisting was primarily channeled through state-owned energy exporters, whereas Beijing targeted a wider range of state-owned and private companies (including, in a 2021 dispute with Lithuania, multinational firms: Appendix 2.39). One potential explanation is that Beijing has more informal channels of influence within firms, such as the system of Chinese Communist Party cells that operate in most large companies (Koss 2021). As discussed above, China also used blacklisting to manipulate outbound tourism flows more frequently than Russia, reflecting differences in the structure of outbound tourism markets and regulation between the two states. In terms of the explanations by firms, one novel justification from the Russian cases is the argument that target state actors had violated contractual provisions—here, firms themselves effectively engage in a form of conversion.

While the ability to blame disruption on the actions of firms complements deniability, one potential disadvantage of this mechanism is the wider scope for compliance gaps, especially where unofficial directions may need to be issued to a large number of firms. If only one or a small number of firms engage in the targeted exchange, blacklists may be effective because governments can credibly threaten to detect defection. This suggests the potential vulnerability of target industries that trade with heavily concentrated industries in China and Russia may be relatively higher. On the other hand, as the number of firms increases and the detection threat becomes less credible, economic actors may ignore directions, and some exchanges may continue. That possibility may make blacklisting less appealing when the logic of the sender’s sanction requires maximizing target costs.

Boycott Fomentation. Boycott fomentation was the least common mechanism for both China and Russia, with the most notable contrast being the greater frequency with which Chinese officials discouraged citizens from outbound travel. There are several plausible explanations for the less frequent use of this mechanism. Insofar as boycotts rely on orchestrating the behavior of large groups of individuals, this type of implementation may simply be harder to control and thus less appealing when alternative mechanisms are available (cf. Wong, Easley, and Tang 2023, 12). Consistent with existing expectations, the observations documented suggest the underlying political dispute needs to be sufficiently salient for ordinary citizens to be mobilized—hence, cases where boycotts featured prominently were ones that occurred against the backdrop of significant public anger, such as China’s 2012 dispute with Japan regarding disputed territory (Appendix 2.15) and Russia’s 2007 dispute with Estonia about the removal of a Soviet-era war monument (Appendix 3.10). Looking across the cases, one variable that appears to facilitate fomentation and which merits attention in future research is the existence of target state firms that are directly implicated in the underlying dispute, as was the case with South Korea’s Lotte (Appendix 2.25) and Sweden’s H&M (Appendix 2.45).⁵⁹

Implications

This section first utilizes the comparative analysis heuristically, drawing inductive inferences for the purpose of refining existing understandings of the different mechanisms through which sender states can implement sanctions while retaining deniability. It then turns to implications for future research and policy.

The four theorized mechanisms through which informal sanctions can be implemented worked well for categorizing China and Russia’s approaches—with one exception. Two Russian cases highlighted a potential fifth mechanism that Beijing does not appear to have utilized, but which may provide deniability under narrow conditions: sabotage (Appendix 3.7 and 3.9). Here officials blame disruption on physical damage to infrastructure that is necessary for exchange to occur, which has been caused by factors beyond their control, such as the actions of third-party insurgents (Appendix 3.7) or other “accidents” (Appendix 3.9). Future research should examine this mechanism more closely, although the sparse examples of its use may indicate it has limited potential. I posit at least two factors that may determine its viability: the existence of economic infrastructure essential for exchange (such as pipelines, electricity transmission lines, or undersea cables) and asymmetry of costs—physically damaging its own infrastructure could involve significant costs for a sender, and while it might enhance the plausibility of denials, it may only be worthwhile if the target relies more heavily on the exchange it facilitates.

Existing scholarship offers few expectations about the conditions under which states will opt for formal or informal sanctions implementation or about the choice among different informal tools. Such decision-making is ripe for further research, and the patterns documented across the cases offer several insights that can guide further theory-building efforts. Regarding formal versus informal, the observations suggest that China and Russia’s baseline preference is for the deniability afforded by informality, and that they only deviate from this when sanctioning reactively against actions taken against them, which can be framed as violations of international law. That hypothesis should be subjected to further testing, which will become easier as more observations of choice become available if the two actors (especially China) continue the apparent trend of more frequent formal sanctions use. Selection among the different mechanisms of informal implementation also merits attention. I have highlighted several advantages and disadvantages of each option that may plausibly inform the logic of choice, including varying levels of deniability and state control over the extent of disruption. How states assess these trade-offs may also be informed by the goal(s) underlying sanctions in different cases (signaling, deterring, compelling, etc.). While there are challenges to identifying specific goals for informal sanctions, future research might attempt to code these and then use this paper’s supplementary data to look for any patterns between specific goals and choice of mechanism.

The analysis also points to new scope conditions on conversion. Earlier research speculated that the viability of this mechanism is contingent on “regulatory availability”: the existence of some framework(s) of rules “which can be discretionally wielded . . . [to] manipulate commerce . . . without explicitly violating international legal rules which prohibit discriminatory restrictions” (Lim and Ferguson 2022, 17). This paper’s analysis of a much larger set of cases allows specification of more precise propositions. In particular, the imposition of restrictions at the border appears to be bound by the scope of rules in four international legal frameworks.

The two most common concerns are SPS and TBT. As discussed above, however, there appear to be limits on the types of exchanges these can restrict. SPS rules provide flexibility to target perishable plant and animal products or processed goods for human consumption (foods and beverages), while TBT regulations pose a risk to products that have undergone processing (packaging, labeling, etc.) and must comply with technical or certification requirements. This is reflected in how heavily agricultural products feature among the industries targeted by both states.⁶⁰ SPS and TBT rules appear to provide limited “regulatory availability” to target products that are less susceptible to pests and disease, are not for human consumption, and undergo minimal processing—such as mineral commodities or trade in services. The two other legal frameworks are AD/CVD rules and the provisions within FTAs; however, given the small number of cases in which these were used, it is difficult to make specific propositions about their availability. That flexibilities built into the WTO regimes for SPS, TBT, and AD/CVD can be exploited by states pursuing narrow interests is well recognized in the political economy literature, however, to date this has largely been explored in the context of protectionism.⁶¹ This issue merits greater attention in research on economic coercion.

Insofar as conversion requires government officials to make an official determination about the application of a rule, the evidence also suggests this style of implementation may be more susceptible to legal challenge than bureaucratic obstruction. While many instances of the latter mechanism documented in the online appendix are arguably measures that violate WTO rules regarding nondiscrimination, none appear to have been formally disputed—instead, each of the WTO disputes emerging from the cases concerns sanctions implemented via conversion.⁶²

The analysis leaves open several promising paths for future research. One, flagged above, is to dig deeper into choice among different mechanisms of informal implementation. Another possibility is to explore how different forms of implementation condition the outcomes generated by China and Russia’s sanctions. Scholars have recently begun seeking to evaluate whether China’s sanctions have generated policy concessions from targets (Zhang and Shanks 2024). While connecting sanctions with such outcomes requires careful process tracing, linking new data on case outcomes with the variation documented in forms of implementation across different episodes may allow researchers to begin teasing out whether any of the mechanisms detailed appear to be more or less effective means of engaging in coercive bargaining.

Finally, “so what” (Byman 2024)? What implications do the findings presented here have for policymakers? First, the patterns of China and Russia’s sanctioning behavior in the past may provide some insight into what might be expected in the future. Many have noted that the two actors, and in particular China, have been expanding their sanctioning toolkit with a variety of news laws in recent years (see, e.g., Xiong 2024, 11–3). This can be seen in the data, with both a general rise in overall sanctioning and a clear rise in the use of formal sanctioning laws. Yet, it is unclear whether these will become their go-to instruments for implementation. So far, Beijing and Moscow continue to only use formal sanctions in the same relatively narrow circumstances that they have in the past: reactively and in a tit-for-tat fashion in response to actions taken against them by Western states.⁶³ While officials currently tasked with building out frameworks for countering coercion should closely monitor how China and Russia use their emerging legal tools, this should not distract their focus from the informal domain, as this is the space where the majority of proactive efforts to make other countries “comply and conform” (White House 2023, 3) have taken—and will plausibly continue to take—place.

The findings presented here suggest one logical place to concentrate is the practice of “conversion,” which dominated and continues to feature prominently in both China and Russia’s approaches to implementation. This mechanism is only viable where rules are sufficiently imprecise that officials possess wide interpretive discretion. Two things might be done to constrain its use. First, policymakers should actively consider what—if anything—can realistically be achieved to narrow some of the flexibilities built into the SPS, TBT, and AD/CVD regimes that have been the object of longstanding criticism. Simultaneously, officials may wish to think about ways to maximize the hypocrisy costs that Beijing and Moscow seem so hung up about avoiding by documenting, seeking explanations for, and, where those explanations have shortcomings, widely broadcasting the most egregious instances where the two countries sanctioning behavior contradicts their anti-sanctions rhetoric. Such efforts should target the apparent audiences of that rhetoric: domestic constituents in China and Russia and Group of seventy-seven states that regularly sign onto their General Assembly statements condemning “Unilateral Coercive Measures.” The less confident China and Russia are about keeping a straight face while issuing those statements, the less audacious they will be in flouting them.

Acknowledgments

For helpful comments, criticism, and suggestions, I am grateful to Viking Bohman, Andrew Chubb, Verónica Fraile del Álamo, Saori Katada, Darren Lim, Keith Preble, James Reilly, Jeffrey Wilson, Jack Zhang, and two anonymous reviewers.

Funder Information

This research was supported by the Japan Society for the Promotion of Science (ID: 23KF0134).

Footnotes

References