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I spent weeks looking into potentially the largest entity to face US OFAC sanctions - Xinjiang Production & Construction Corps 新疆生产建设兵团, thx to input from @RocafortFred @nuryturkel Sarah Wronsky & Shih Chienyu. Here's what I found https://www.scmp.com/news/china/diplomacy/article/3098490/xinjiangs-sprawling-conglomerate-may-be-biggest-ever-face-us
As @RocafortFred said, XPCC is a weird beast. It started as a paramilitary org for defending China's nw borders & developing the frontier. It's grown to a massive entity that counted for 20% of XJ's GDP in 2019. James Seymour's paper expands on its history https://www.jstor.org/stable/23615556?seq=1#metadata_info_tab_contents
The US sanctioned XPCC & 3 of its officials for human rights abuses. 2018 @UyghurProject project said XPCC effectively colonised XJ thru large-scale Han migration, marginalisation of Uygur workforce, force demolition of Uygur homes & more https://uhrp.org/press-release/uhrp-releases-new-report-%E2%80%98-bingtuan-china%E2%80%99s-paramilitary-colonizing-force-east
The sanctions are a right move but enforcing them won't be easy. @SayariLabs found thru public records that XPCC has stakes in over 800,000 holdings in 147 countries. Altho which of these are majority-owned, the threshold for sanctions, are not clear yet https://sayari.com/blog/u-s-sanctioned-xinjiang-paramilitary-owns-over-800000-subsidiaries-worldwide/
XPCC's cotton exports will be hit, many hv reported. But an area that deserves more attn is its tomato production. The XJ region produces as much as 17% of the world's tomatoes. China's biggest tomato export companies, XJ Chalkis, is owned by XPCC https://news.cgtn.com/news/2019-10-17/Your-ketchup-probably-comes-from-Xinjiang--KQdXzT7PJS/index.html
At 1 stage XJ Chalkis claimed it had 45% share of EU's packaged ketchup mkt & 60% of 1 of the segments in Africa. But in recent years Chalkis has been embroiled in financial scandals & its business has suffered http://finance.sina.com.cn/stock/s/20051019/15482046494.shtml
This would be why in the @CECCgov 2020 report on supply chains & XJ, Campbell Soup & others were listed as companies "suspected of
directly employing forced labor or sourcing
from suppliers that are suspected of using forced
labor" https://www.cecc.gov/sites/chinacommission.house.gov/files/documents/CECC%20Staff%20Report%20March%202020%20-%20Global%20Supply%20Chains%2C%20Forced%20Labor%2C%20and%20the%20Xinjiang%20Uyghur%20Autonomous%20Region.pdf
directly employing forced labor or sourcing
from suppliers that are suspected of using forced
labor" https://www.cecc.gov/sites/chinacommission.house.gov/files/documents/CECC%20Staff%20Report%20March%202020%20-%20Global%20Supply%20Chains%2C%20Forced%20Labor%2C%20and%20the%20Xinjiang%20Uyghur%20Autonomous%20Region.pdf
Even tho XPCC is besieged by a range of problems, BJ cont' to cover more than 90% of its budget, as it is critical to the CCP's governance of XJ & for its role as a conduit to Central Asia for the Belt & Road Initiative, acc to scholar Bao Yajun https://www.bsg.ox.ac.uk/research/publications/xinjiang-production-and-construction-corps
But the sanctions cld put a dent in XPCC's BRT ambitions, as foreign businesses & US entities cld face punishment for dealing w/ XPCC. The corps & its partners submitted a proposal in 2018 to rehabilitate 3,000 ha of farmland in Mozambique https://www.forumchinaplp.org.mo/chinese-joint-venture-eyes-rehabilitation-of-farmland-in-mozambique/
In 2013, XPCC signed a deal to reportedly invest in 3 mln ha of Ukrainian farmland, which was later clarified to be a deal w/ a Ukrainian company supplying irrigation tech to XPCC. But this kind of deal wld be impacted by sanctions https://www.reuters.com/article/china-ukraine/china-to-invest-in-3-mln-hectares-of-ukrainian-farmland-media-idUSL3N0HI04620130922
Perhaps an example of aid diplomacy: In 2012, XPCC signed a MOU w/ Angola to develop an agritech centre. Angola was 1 of the 37 countries that signed a letter supporting CN's policies for XJ https://agritrop.cirad.fr/582983/1/ATDC%20Paper.pdf
Ultimately, while int trade cld be cut off, observers were not optimistic abt the sanctions curbing rights abuses by XPCC & enforcement remains challenging. Given only a small fraction of XPCC dealings is out in public domain, we need to cont' to monitor the corps
To end, vid by regiment 54 of XPCC 3rd division, 1 of the few I cld find on how the corps interacted w/ their Uyghur neighbours, edited to suggest the Uyghur farmers were impoverished & needed help while the XPCC official strutted thru their home like he owned the place
