The US Take State-Action Against China For The Coronavirus?
The US Take State-Action Against China For The Coronavirus?

The US Takes State-Action Against China For The Coronavirus?

Coronavirus is continuing to disrupt global economy and the lives of the citizens of the World.
Coronavirus is continuing to disrupt global economy and the lives of the citizens of the World.

Coronavirus is continuing to disrupt global economy and the lives of the citizens of the World. Until today, unilateral declarations of states against China for its malign activities in concealing the facts regarding the source of the virus are pretty much all we have witnessed.

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Research by Kemal ÜNAL

Currently -especially in US politics– there is a debate on the legal grounds for action against the Chinese government under public international law. However, these debates lack the ability to set forth the main legal grounds for action against China.

Therefore, these discussions seems to be used for domestic political purposes by the Biden administration, just like Trump. In this vein, instant action under public international law seems unlikely, however these legal mechanisms will be highly relevant in shaping the future of US-China relations. An important factor that must be kept in mind is that international public law remedies usually require the acceptance of jurisdiction of the counter-party. Thus, states usually tend to take action by way of sanctions, rather than forcing remedies under public international law. This article aims to set forth relevant legal bases for state action by the US against China and whether the Biden administration will truly initiate these mechanisms.

Coronavirus, Covid-19 or the Chinese Virus as Donald Trump repeatedly called. A deadly virus that appeared in Wuhan, China, a region that hosts China’s only biosafety level-four super lab. As far as we know, there are more than 153 million confirmed cases and 3 million casualties worldwide, unfortunately with many more underway. Besides, these numbers in fact are much higher when it is considered that a lot of countries are not transparently reporting and are failing to disclose real numbers, either due to incompetence or intentionally misleading the public for economical purposes.

Let’s not forget that China claimed that Wuhan defeated the virus and had not reported even a single case for weeks. This is really absurd and is like a joke! These days are showing us that autocratic governments are posing the greatest threat to the World and the offering that autocracy concerns only the citizens living under the rule of the regime is proven wrong. The situation is even more terrifying than it seems when it is considered that the casualties occurred during Chinese Communist Party’s (“CCP”) efforts of concealing the virus when first detected are also not included in these numbers.

Moreover, the CCP is still pursuing its policy of creating global disinformation. It is necessary to be cautious when assessing data in relation to Covid-19, most of the numbers are unreliable. Many scientific offerings failed in this period, one by one. There are mainly 2 reasons for this; i) global disinformation, ii) complex ability of the virus to mutate. Yet, contrary to what some claim, Covid-19 cannot be assessed as SARS, influenza A (H1N1) or H5N1 (bird flu). We are facing something different, more pathological.

Who Is to Blame?

There are rumours that this might be a specially produced virus. The rumours are spouted by both US and Chinese sources. So, are US and China on the same page? Not really… US blames China, China blames US. US sources’s points can be understood since the virus is sourced in Wuhan that hosts China’s only biosafety level-four super lab. Combined with CCP’s relentless silencing of the brave people who tried to inform the international community, it is obvious that US sources have a point in claiming that the virus might be Chinese-made.

“I would note that Wuhan has China’s only biosafety level-four super laboratory that works with the world’s most deadly pathogens to include, yes, coronavirus.”

US Senator Tom Cotton tweeted in January 30, 2020.

On the other side, China’s foreign ministry ridiculously accused the US soldiers of bringing the virus to Wuhan. However they (not surprisingly) failed to present any evidence. CCP’s accusation against the US is absurd and cannot be taken seriously. However, this accusation of the CCP was actually a perfect example of the authoritarian-communist regime mindset,Never hesitate to lie, no matter how absurd or baseless it is.”

This mindset is the main source of the troubles the World is facing. Just like the worldwide spread of Covid-19. It is ridiculous to see some people seek countries to blame other than China for the severity of the Covid-19. Accusations against countries other than China for the Coronavirus outbreak is not only absurd, it further shows that – unfortunately – Chinese efforts of smearing are working. In addition, financial difficulties that people are facing due to the Coronavirus are supporting the smearing activities of China, since people tend to blame the liberal financial system for the difficulties they are facing.

Let’s not fall for that, communist regimes are not helping even their own citizens, just look at the labor wages & conditions in China and see for yourself. The culprit for both the pandemic and current financial challenges is obvious, it is China!

Ongoing Discussions in Us Politics to Hold China Accountable

There are clear evidences showing that the CCP concealed the existence of the virus as well as transmission capabilities of it. Moreover, whistleblowers like Li Wenliang are silenced and the international community was informed by China when it was too late. Non-transparency, censorship and silencing, 3 tactics relentlessly embraced by the CCP, led to this disaster.

A lot can be written about corrupt practices and cover-up efforts of the Chinese government. In this vein, there are rightful demands in the US to hold China accountable. Especially in the US Senate, there is a strong preparation to create a compensation mechanism against China. Senator Josh Hawley introduced a bill that will provide an international investigation on China and a compensation mechanism. In the same direction, Senator Lindsey Graham told that China must “pay big time” and further added “The whole World should send China a bill for the pandemic.

This is the third pandemic that comes out from China.” Graham is totally right! In the same direction, Tennessee Senator Marsha Blackburn stated that China hid Covid-19 and refused to act transparently. Ms. Blackburn further added that the Senate must pass a resolution to hold China responsible and that the US should ask China to waive some of US debts (amounting to nearly 1 trillion US dollars) owned by China for the damage the CCP caused by concealing the virus.

Thirdly, Ms. Blackburn offered bringing back the manufacturing components to the US, which is a really popular (and rightful) opinion nowadays, not only for the US, but also other countries. When the suggestion of Ms. Blackburn to ask China to waive some of US debts is tackled, it seems practically ineffective since China will never accept such proposal or the jurisdiction of US courts. However, a lot of discussions are ongoing in relation to what can be done about the US debts owned by China, since China will most probably use these debts to disrupt US economy in case if US takes severe actions against the CCP.

In addition to these debates, various class actions are being initiated in the US against China to compensate financial losses amounting to billions of dollars due to Covid-19. However, please note that the Foreign Sovereign Immunities Act foresees state immunity for foreign countries, with certain exceptions regarding commercial activity in the US.

Therefore, a binding ruling on China cannot be made in the US Courts. Thus, tackling China’s responsibility under public international law is more realistic. Some critics of China are demanding the US to cancel some portion of the 1.1 trillion US dollars (approximately) of US Treasury debt owed to China. Senator Lindsay Graham openly declared that the US must cancel some part of these debts owed to China to be set-off from the damage caused by Covid-19.

However, this proposal seems practically impossible to implement since these debts are under the guarantee of the US government, thus US is not entitled to refuse to pay these loans. Furthermore, such a move by the US will have devastating effects on global economy, and would further destroy US’s financial credibility and domestic economy. Japan already started working on shifting production out from China by setting aside an economic support package.

Japan is working successfully and rapidly to reduce reliance on China, this is what all the World must do! International community can no longer maintain the system of reliance on China! American manufacturing can also be shifted across other countries in the Asia-Pacific region and the Middle East, rather than shifting the whole production to the US. Indeed, wholly shifting the production facilities to the US will be a costly process, when the labor costs in China are taken into account. By doing so, the US will be able to gain trust and allies that geopolitically will be critical for confronting China (Let’s keep in mind that the US is shifting its military assets to the Asia-Pacific and a direct military escalation in the South China Sea is being discussed louder than before).

However, the ultimate way of shifting production out from China can be done by providing incentives, since those are private American companies with the freedom to determine commercial activities. On the other hand, a serious source of funds must be spared by the US government in order to provide competitive advantages against labor costs in China. The CCP is not changing course to act as a normal state that complies with its obligations under international law, thus China must be confronted and held accountable. Otherwise, there are more to come from China to cause devastating damage to the World.

China is the biggest threat to global health; thus, the World must take collective action against China. Yet, majority of the countries in the World (including major European Union members such as Germany and France) are refusing to even make any declaration against China for basically financial concerns. It is even more disturbing and concerning to see the European states’s ignorance of China’s malign activities and act as if nothing happened. What happened to European values? Is trade a higher value than human health for the European Union? It seems so! EU and US must give a collective response against China to hold the CCP accountable and make the CCP pay for the damage it caused.

Various Legal Actions That Can Be Taken Against China by The Us Under Public International Law

There are rightful demands for the Chinese government to be held accountable by the international community. However, there is no sufficient debate on the legal grounds and background for this. Former president Trump and his staff were constantly talking about holding China accountable for this outbreak, but did so little besides imposing sanctions (which majorly lacks the ability to practically deter the CCP).

Biden seems too focused on domestic challenges and is not too harsh against China as per the origins of Covid. This way or that, political declarations to hold China accountable for Covid lacks reference to the legal grounds thereof. In this article, various legal actions that can be initiated against China by the US will be tackled from a public international law perspective.

CCP is continuing to reject an international investigation on the origins of the Coronavirus. The reason for China’s total rejection and silencing policy is CCP’s wrongful conducts to conceal the virus. Therefore, there is no international investigation done in relation to the Coronavirus outbreak yet. However, there are clear evidences showing China’s malign activities.

There are 2 possible origins of the Coronavirus as far as detected by the international community. Covid-19 might be originated;

  • from a wild animal market (which is the popular opinion), or
  • from the biosafety level-four super lab in Wuhan (in form of leakage).

In this context, various legal actions that can be taken against China by the US are tackled below. Please note that the following explanations are made through a legal perspective, therefore, as some claim, the US might not take such actions at all against China for financial reasons.

Indeed, by maintaining Trump’s sanctioning diplomacy, the US most probably will take actions against Chinese entities and individuals who are allegedly involved in cover-up activities rather than taking actions against China under public international law. However, please note that sanctioning Chinese individuals and entities will not create the same effect as international proceedings that will confirm the liability of China. In other words, since executive orders are unilateral decisions of the US, those documents lack the ability to create a binding effect.

Thus, sanctioning individuals and entities with unilateral decisions (mostly by way of Executive Orders) will create a problem since we have all witnessed that (with respect to reimposed sanctions on Iran) a lot of countries tend to keep up business as usual despite US sanctions. Please further keep in mind that Trump’s unplanned sanction diplomacy undermined the future effects of US executive orders.

Convention on the Prohibition of the Development, Production and Stockpiling of Bacteriological (Biological) and Toxin Weapons and on their Destruction

China is a state-party to the Convention on the Prohibition of the Development, Production and Stockpiling of Bacteriological (Biological) and Toxin Weapons and on their Destruction or shorty Biological Weapons Convention (“BWC”). BWC is a United Nations Convention within the United Nations Office for Disarmament Affairs. China – as a state party – is obliged to comply with the BWC terms thereof. BWC is an arms control treaty.

The US Take State-Action Against China For The Coronavirus?
The US Take State-Action Against China For The Coronavirus?

Thus, one might claim with a straightforward approach that pandemics or epidemics fall outside the scope of application of the BWC, since they are causes of nature and are not weapons. In such an approach, the Coronavirus will not be tackled under the BWC. However, a legal interpretation of the convention requires a different conclusion.

“Determined, for the sake of all mankind, to exclude completely the possibility of bacteriological (biological) agents and toxins being used as weapons”

The preamble of the BWC contains the phrase;

Therefore, the preamble of the BWC also focuses on the “usage” of biological agents, and not only the production of bacteriological (biological) and toxin weapons. Thus, even a grammatical interpretation leads to the conclusion that the usage of a particular biological agent as a weapon falls within the scope of the BWC. Therefore, the suggestion that Covid-19 is not produced as or not intended to be a biological weapon by China is not sufficient to prevent claims under the BWC against China. In this context, Coronavirus cannot be interpreted as to fall outside the scope of the BWC per se.

The US Take State-Action Against China For The Coronavirus?
The US Take State-Action Against China For The Coronavirus?

Article I of the BWC reads as;

“Each State Party to this Convention undertakes never in any circumstances to develop, produce, stockpile or otherwise acquire or retain:

  1. microbial or other biological agents, or toxins whatever their origin or method of production, of types and in quantities that have no justification for prophylactic, protective or other peaceful purposes;
  2. weapons, equipment or means of delivery designed to use such agents or toxins for hostile purposes or in armed conflict.”

As seen in this provision, the Coronavirus outbreak can be tackled under BWC Article I (1), provided that China’s actions led to this pandemic.

Developing, producing, stockpiling, acquiring and retaining are all prohibited actions under Article I (1) of the BWC, provided that the types and quantities of the relevant biological substances cannot be justified under “prophylactic, protective or other peaceful purposes.” The provision sets forth 2 indicators as quantity and type.

On one hand, the term “quantity” shall be interpreted as “amount.” The provision does not indicate a specific “amount or range” for “developing, producing, stockpiling or otherwise acquiring or retaining” biological substances that is justifiable under “prophylactic, protective or other peaceful purposes.” However, a teleological interpretation shall require this amount to be negligible (de minimis).

Article I (1) of the BWC shall be interpreted on the basis of De minimis non curat lex principle (meaning “trifles are not the subject of law”). Accordingly, amounts of biological substances shall be tolerated as long as they are unable to be used to harm human, animal or plant health. Indeed, this is basically an exception that is needed for scientific research and improvement. On the other hand, the term “type” shall be interpreted as “characteristics.

Therefore, “developing, producing, stockpiling or otherwise acquiring or retaining” biological substances that are harmful for human, animal or plant health are “in principal” unjustifiable under “prophylactic, protective or other peaceful purposes.” In this sense, BWC is recognising the importance of scientific developments and state parties’s rights to work with biological agents for “peaceful purposes” and economic & technological development. Article X of the BWC reads as:

“(1) The States Parties to this Convention undertake to facilitate, and have the right to participate in, the fullest possible exchange of equipment, materials and scientific and technological information for the use of bacteriological (biological) agents and toxins for peaceful purposes. Parties to the Convention in a position to do so shall also co-operate in contributing individually or together with other States or international organisations to the further development and application of scientific discoveries in the field of bacteriology (biology) for the prevention of disease, or for other peaceful purposes.

(2) This Convention shall be implemented in a manner designed to avoid hampering the economic or technological development of States Parties to the Convention or international co-operation in the field of peaceful bacteriological (biological) activities, including the international exchange of bacteriological (biological) agents and toxins and equipment for the processing, use or production of bacteriological  (biological) agents and toxins for peaceful purposes in accordance with the provisions of the Convention.”

However, proving the purpose (or intent) is quite challenging and one might easily claim that its purpose is as stipulated in law. In terms of biological research, states have the sovereign right to conduct scientific activities for producing medicines or contributing to science in different ways, as well as pursuing legitimate goals of economic & technological growth. These goals are recognised by the BWC.

The US Take State-Action Against China For The Coronavirus?
The US Take State-Action Against China For The Coronavirus?

Combined with public international law’s character of granting every country sweeping sovereign rights, proving the intent of a state as “not peaceful” (hostile) is usually difficult. In this direction; provided that it is proven that Chinese scientists intentionally developed or produced the Coronavirus to cause casualties, there is no doubt that this action would be a violation of the BWC.

Furthermore, this provision prohibits “acquiring” of biological agents. And by using the word “otherwise,” the provision sets forth illustrative examples, thus actions stipulated under this provision are not numerus clausus (limited in number). In this context, Chinese scientists’s acquiring of the Coronavirus for hostile purposes shall be interpreted as to fall under the scope of this provision.

However, there is currently no clear data showing that the Coronavirus was intentionally manufactured as a biological weapon by China. In such an assumption, as stated above, China would undoubtedly be liable under the BWC. Moreover, China’s rejection of an international investigation raises more concerns in this sense. The biosafety lab in Wuhan must be closely investigated in order to tackle this issue under the BWC.

Provided that Covid-19 sourced from the biosafety lab in Wuhan by way of leakage; China can be held accountable for stockpiling the Coronavirus provided that it cannot justify the amount of the virus contained in the lab for “prophylactic, protective or other peaceful purposes.” There is no doubt that the “type” of the Coronavirus is not justifiable under Article I (1) since its deadly biological agent. Therefore, the “amount” must be tackled. Thus, as indicated above, type and quantity of the pathogen shall be collectively considered since the provision reads as “of types, and in quantities.”

Therefore, provided that the Coronavirus (in an amount that cannot be justified under peaceful purposes) was stockpiled in the Wuhan lab and could not be contained there, US can lodge a UN Security Council complaint against China. Tackling “amount” of a specific pathogen will surely require a scientific assessment, however legally, as stipulated above the “quantity” of the stockpiled virus must be negligible (de minimis). The questions that must be answered by scientists are the following:

  • Is this amount of pathogen really necessary for conducting research or experiment?
  • Does this quantity of pathogen exceed the minimal amount needed to conduct scientific research and experiment?

It must also be underlined that this assessment will to some extent depend on the desired scientific result declared by the relevant state (China) since proving the intent of a state in a specific direction is usually not possible (for example, an experiment to reach result A might require more pathogens than an experiment to reach result B).

Provided that Covid-19 sourced from the wild animal market in Wuhan; China’s non-reporting (and concealing activities) can be tackled under “retention”, which is also a prohibited action under Article I of the BWC (to … retain), since there is no stockpiling of the pathogen in this scenario and the virus emerged due to biological reasons sourcing from the conditions in the wild animal market.

“Retention,” as well as development, producing, stockpiling and acquiring, is prohibited under Article I of the BWC. Thus, Chinese government’s inaction that led to non-reporting can be considered as a form of retention. In other words, China’s non-reporting led to the continuance of the state of retention of the Coronavirus, as well as the information in relation to the virus. At this point, it’s of utmost importance to underline that it’s irrelevant whether the CCP’s inaction or non-reporting is intentional or not.

Therefore, by putting forth the evidences in relation to both scenarios, a Security Council complaint can be lodged against China by the US. This action shall be initiated in accordance with Article VI (1) of the BWC.

WHO Constitution & International Health Regulations

China, as a member of the WHO is obliged to comply with the International Health Regulations (2005) Third Edition (“IHR”) and the WHO Constitution. IHR is a binding guideline for all WHO members that regulates detection, assessment and reporting of public health events. In this vein, according to the IHR, states are obliged to notify the WHO of events that constitute “public health emergency of international concern.” Article 1 of the IHR defines “public health emergency of international concern” as:

“An extraordinary event which is determined, as provided in these Regulations:

  1. to constitute a public health risk to other States through the international spread of disease and
  2. to potentially require a coordinated international response”

Thus, as seen by the definition, the Coronavirus is undoubtedly a “public health emergency of international concern.” Article 6 of the IHR sets forth that a state shall notify the WHO of a public health emergency of international concern “within 24 hours of assessment of public health information, of all events which may constitute a public health emergency of international concern within its territory.” Thus, the provision determined a deadline for the notification of the public health emergency of international concern.

However, it is obvious that China missed the deadline by notifying the WHO more than a month later (in the best assumption). Therefore, it is evident that China violated the notification obligation by not notifying the WHO within the period indicated in the IHR. It must also be indicated that the source of the Coronavirus (either the wild animal market or the biosafety lab in Wuhan) shall not be relevant since the violation is in relation to the notification obligation.

According to IHR Article 56 titled “Settlement of disputes, states are obliged to seek reaching a settlement by peaceful means in the first place in disputes arising from the IHR. If no settlement is reached by peaceful means, states may agree to refer the dispute to WHO Director-General and in this case, the Director-General shall make effort to settle the dispute. Provided that the parties accept arbitration as compulsory, Permanent Court of Arbitration Optional Rules for Arbitrating Disputes between Two States (“Arbitral Tribunal”) shall be authorised to settle the dispute. It must also be noted that the decision of the Arbitral Tribunal shall be binding and final for the parties.

However, please note that since China will most likely reject the authority of the Arbitral Tribunal. Thus, initiating the procedure foreseen in Article 56 of the IHR would not be effective. According to Article 64 of the WHO Convention;

“Each Member shall provide statistical and epidemiological reports in a manner to be determined by the Health Assembly.”

Thus, China’s failure of timely notification leads to the breach of this provision, as well as the IHR as stipulated above. Article 75 of the WHO Constitution contains explicit reference to ICJ’s jurisdiction with the following provision;

“Any question or dispute concerning the interpretation or application of this Constitution which is not settled by negotiation or by the Health Assembly shall be referred to the International Court of Justice in conformity with the Statute of the Court, unless the parties concerned agree on another mode of settlement.”

Please further note that the Article 21 of the WHO Constitution refers to IHR. ICJ’s jurisdiction will be further assessed in the following.

Convention on International Trade in Endangered Species of Wild Fauna and Flora

China and the US are both parties to the Convention on International Trade in Endangered Species of Wild Fauna and Flora (“CITES”). First of all, legal action under CITES can only be initiated if it is proven that the Coronavirus sourced from the wild animal market (thus, due to wild animal trade). A leakage of pathogen from the biosafety lab in Wuhan would not fall within the scope of legal action under the CITES.

Before starting to tackle the possible legal actions, it must be stated that wild animal markets are problematic under CITES and that China is often faced with objections from other parties to the convention. China is constantly violating its obligations arising from this convention by refusing to act in compliance through claiming that wild animal trade is a part of the Chinese culture. This response of the Chinese government is legally unacceptable. Therefore, China is violating its obligations under CITES by allowing illicit trade and sale of wild animals.

In this context, US can act against China according to Article XVIII of the CITES titled “Resolution of Disputes. According to Article XVIII of the CITES, disputes arising from the CITES shall be subject to negotiation between the parties in the first place.

If the dispute is not resolved through negotiation, parties (…) may, by mutual consent, submit the dispute to arbitration, in particular that of the Permanent Court of Arbitration at The Hague, and the Parties submitting the dispute shall be bound by the arbitral decision. Thus, CITES (just like the IHR) will be ineffective, basically since China will not accept the authority of the Permanent Court of Arbitration at the Hague.

Please further note that the CITES Secretariat made a statement in relation to Covid-19 and stated that zoonotic diseases are not within the authority of the CITES. However, this declaration seems to be made by a political motive (since it is not yet proven that the virus sourced from the wild animal market). Legally, it must be reasonable to initiate legal action against China under the CITES.

This way or that, China’s wild animal market clearly violates the CITES, since pangolins are are included in CITES Appendix I, and that the commercial trade of these animals are prohibited. Thus, even if not under the mechanism set forth under the CITES, US is able to commence legal action against China based on the breach of CITES under other international bodies.

Statute of the International Court of Justice

As stipulated above, China’s actions in relation to Covid-19 violated several obligations arising from international law. Thus, bringing a case to the International Court of Justice (“ICJ”) against China is theoretically possible. According to Article 36 of the Statute of the International Court of Justice (“Statute”), states may bring cases to be settled by the ICJ, provided that both states accept the jurisdiction of the ICJ.

The acceptance of jurisdiction of the ICJ can occur in 3 ways;

  • Declarations of acceptance of jurisdiction: According to Article 36, paragraphs 3-4 of the Statute, states may accept the jurisdiction of the ICJ by way of declarations deposited with the Secretary-General of the United Nations.
  • A special agreement made to resolve the dispute in ICJ: States can sign agreements to accept the jurisdiction of ICJ on matters contained in the special agreement.
  • Treaties containing provisions accepting the jurisdiction of the ICJ: States can accept the jurisdiction of the ICJ by virtue of another treaty. Thus, if a treaty in force refers to the jurisdiction of the ICJ, the relevant provision is able to confer jurisdiction to the ICJ.

In this case, first and second paths of jurisdiction seems unlikely to be initiated since they require a separate acceptance of ICJ’s jurisdiction by China. However, the third path might be initiated. China has ratified the WHO Constitution which contains explicit reference to ICJ’s jurisdiction with the following provision (Article 75);

“Any question or dispute concerning the interpretation or application of thisConstitution which is not settled by negotiation or by the Health Assembly shall be referred to the International Court of Justice in conformity with the Statute of the Court, unless the parties concerned agree on another mode of settlement.”

Thus, initiating legal action against China under the WHO Regulations seem practical and possible. However, the ICJ does not have a mechanism & power to force the execution of its decisions. Therefore, even if China is brought in front of the ICJ, the CCP might refuse to execute the ruling.

Conclusion

The Coronavirus pandemic affected every country in the World, both in terms of economy and obviously human health (thus demographically). Besides, the World is at the edge of a total recession. We are already in a cycle; strong economies which manufacture are not able to find markets for their goods & services and they will gradually cut production. Production is becoming a burden for productive economies such as Germany, France and the US, they can’t sell, or find new markets for their goods & services.

Weak economies do not have the financial sources to basically purchase these goods & services anyways. This is the simplest way of understanding why the post-Covid era will be a true challenge for the World financial system. Moreover, a majority of legal remedies that can be commenced against China requires China’s approval of jurisdiction. This is a fundamental problem under international law that lacks the ability to deter countries from violating international conventions.

Furthermore, a full-on confrontation against China may have severe effects on the US economy, as well as the World financial system, since China would most probably not hesitate to use the US Treasury bonds as leverage. Therefore, Biden (just like Trump) is more likely to aim at Chinese individuals and entities by way of “sanctioning,” rather than taking actions directed at the Chinese government.

Research by Kemal ÜNAL