Can a foreign country's sanctions on US individuals compel the US banks or companies to cut ties or not do business with them (even on US soil)?

For e.g. China, in January, sanctioned Mike Pompeo, John Bolton and many other Trump administration officials. The sanctions' details say that "any institution or entity associated with them will be blocked from doing business in China".

So for e.g. say that Mike Pompeo has a bank account in JPMorgan or any other banks who do business in China. So does that mean that JPMorgan or others will be banned from doing business in China? Also, wouldn't they ever finance/do business with Pompeo even on US soil and freeze his account which is physically on US soil? And does that mean JPMorgan is automatically barred from doing business in China because that's what Chinese sanctions mean and it also can't freeze Pompeo's account as it has a legal obligation to him under US law?

More interestingly, the details also include "any entity". So, will Pompeo not be able to buy goods/services or do anything with them? The details also include "institution". So will no university/college/organization be able to employ them even on US soil or anywhere globally? And what about any third party (non-US, non-Chinese) institution or entity?

Does that also mean Pompeo and others sanctioned can't be employed in a US/foreign company that has business in China?

Is my understanding wrong?

  • 1
    The answer is depending on China's determination and will to make it difficult for the livelihood of the named persons, which nobody can speculate.
    – r13
    Commented Apr 4, 2021 at 19:29
  • @r13 That sounds like China's intent. They'd probably like to imprison them. But since they can't, they'll just use pressure tactics to make their professional and financial lives terrible.
    – Barmar
    Commented Apr 4, 2021 at 21:19
  • I guess Donald Trump is a few dollars poorer now, as the Chines might have frozen his interests/holdings in China if this NYT/CNN report is true. cnn.com/2020/10/20/politics/trump-china-taxes-financial-records/…
    – r13
    Commented Apr 4, 2021 at 21:42
  • I wonder what would happen if Mr. Pompeo is detained by the Chinese on a business trip :)
    – r13
    Commented Apr 5, 2021 at 0:50
  • I don't want to distract the attention on this matter, but couldn't stop to think what would happen if Trump, or Pompeo, is elected to be the next President :)
    – r13
    Commented Apr 5, 2021 at 0:53

1 Answer 1


Potentially, yes. It would be interesting to find out how China draws the list of associated entities, and if a major US bank would rather retain their ties with China or with a former administration official. The US used such sweeping sanctions in a few cases, like Iran and North Korea, but then forgoing business with North Korea is usually no big deal.

As I understand the news reports, in this case the Chinese sanctions are not that sweeping. They would hit companies owned by the listed individuals, however.

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