If you saw the recent statements made by prominent Members of the US Congress, pointing out how banks in Hong Kong are assisting Russia in evading international sanctions, and facilitating payment for illicit Iranian oil shipments, and Hong Kong's quick but terse denials, you know that it's time for American banks to raise risk levels on the former British territory. We completely agree, and also remind readers that both of the Chinese CBI companies that illegally diverted billions of dollars from programs in Saint Kitts and in Saint Lucia, directly to Hong Kong's banks.
If this means you must raise Country Risk on China itself, then do it. otherwise, you increase the chances that your bank will unwittingly fall victim to assisting in the evasion of international sanctions, or something even worse. Those US Congressmen are dead right on this; believe them, and act accordingly if you are a compliance officer at a US bank with substantial international trade clients.
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