Steelman · slot C
Extraterritorial reach without evidence
A Chinese trade-policy analyst would argue —Washington has designated a Dalian refinery without producing the factual or legal basis for the claim, and is now demanding that a Chinese company governed by Chinese law reorganize its commercial life around an American executive order. Hengli's suppliers contractually guarantee non-sanctioned origins; if the US has evidence to the contrary, let it produce that evidence in a forum where it can be tested. Instead we get a listing, reputational damage, and pressure on third-country banks to fall in line. This is the core problem with the secondary sanctions architecture: it treats the entire global refining industry as subject to US jurisdiction, then shifts the burden of proof onto the sanctioned party to disprove an unstated allegation.