The Office of Foreign Assets Control placed Xinjiang Production and Construction Corporation on its Specially Designated Nationals List on July 31.  XPCC’s placement on this list means that all U.S. entities or non-U.S. entities subject to U.S. jurisdiction (covered persons) are now banned from engaging, directly or indirectly, with XPCC without a license from OFAC. 

XPCC was added to the SDN List for serious rights abuses against ethnic minorities in China’s Xinjiang Uyghur Autonomous Region. XPCC engages in cotton farming and sales in XUAR for certain types of cotton. China accounts for 20 percent of all the cotton in the world and XUAR accounts for 80 percent of China’s cotton. This production represents 50 percent of global spinning capacity.

OFAC may consider any transaction by a covered person that directly or indirectly benefits XPCC as a violation of these sanctions, including apparel-related transactions made anywhere in the world that contain XPCC cotton.   

A general license is available through Sept. 30 for companies to wind down their supply chains to exclude XPCC. However, details regarding any transactions or activities necessary to the wind down of transactions involving XPCC subsidiaries that are authorized under the general license, including the names and addresses of the parties involved, the type and scope of activities conducted, and the dates on which the activities occurred, must be reported to OFAC by Oct. 14.

For more information on these sanctions and how they may affect your specific supply chain, please contact Kristine PirniaTom Travis, or Nicole Bivens Collinson.

Copyright © 2024 Sandler, Travis & Rosenberg, P.A.; WorldTrade Interactive, Inc. All rights reserved.


Thomas G. Travis
Founder and Counsel
Kristine Pirnia
Partner, Advisory Committee; Export Controls & Sanctions Practice Leader
J. Nicole Bivens Collinson
Managing Principal, Operating Committee; International Trade & Government Relations Practice Leader

ST&R: International Trade Law & Policy

Since 1977, we have set the standard for international trade lawyers and consultants, providing comprehensive and effective customs, import and export services to clients worldwide.

View Our Services


Cookie Consent

We have updated our Privacy Policy relating to our use of cookies on our website and the sharing of information. By continuing to use our website or subscribe to our publications, you agree to the Privacy Policy and Terms & Conditions.