Project 2025 Tracker / What’s done, what’s next

26. Trade · Notable · Contested — excluded from counts

Sanction companies that facilitate China's Great Firewall

Not started

790 26. Trade · from “The Case for Fair Trade”

“Sanction any companies, including American companies like Apple, that facilitate Communist China’s use of its Great Firewall surveillance and censorship capabilities.”

What has happened

  1. Not started

    No company, American or otherwise, has been sanctioned for facilitating the Great Firewall. Federal Register full text since 2025-01-20 returns zero documents in any type for "Great Firewall"; the bills Corpus has no bill using the phrase; OFAC's sanctions programs as listed on 2026-09-01 include no China censorship or surveillance program, and the recent-actions feed for August 2026 is Iran, Venezuela, Russia, Cuba, counter-terrorism and counter-narcotics. The administration's China capital and technology instrument, the America First Investment Policy memorandum of 2025-02-21, is about investment and auditing and does not mention censorship, surveillance or the companies that supply them. **The limit the earlier pass stated has now been closed (read-queue ticket 07, 2026-09-06): every designation has been checked, and the answer is still no.** OFAC's Specially Designated Nationals list was downloaded in full - 19,329 rows - and contains no Chinese censorship or surveillance vendor: Hikvision, Dahua, SenseTime, Megvii, iFlytek, Semptian, Meiya Pico, Qihoo, Knownsec, Chengdu 404 and Huawei each return zero, and so do the words "surveillance" and "censorship". The only two Chinese cyber firms on the list are Integrity Technology Group and Sichuan Silence Information Technology, both under the CYBER2 program and both designated **before** the window opened - 2025-01-03 and 2024-12-10 respectively, seventeen and forty-one days early. OFAC's Recent Actions index has a working full-text search after all, and it was run: "Great Firewall" returns zero results across all 3,152 announcements, "censorship" returns one from 2012 about Burma, and "surveillance" returns four, the newest of which is a March 2025 counter-terrorism action. Filtered to actions on or after 2025-01-20, "China" returns 73 announcements and none of the vendor names returns any.

    No action found yet. This entry is the starting point, not a finding.

Research log

What was searched, and what didn’t count as evidence

Research notes

The Quote is unusual in naming an American company - Apple - as a sanctions target. Nothing in the window comes close: the export-control side of the China program (Entity List additions of 2025-03-28, 2025-09-16, 2025-10-09 and 2025-11-12, and the affiliates rule of 2025-09-30, itself suspended for a year on 2025-11-12) restricts what may be exported to listed Chinese entities; it does not sanction firms for helping the Firewall operate.

ofac.treasury.gov answers 200 to a bare curl and is the readable Treasury sanctions host - home.treasury.gov/policy-issues/financial-sanctions/recent-actions 302s away.

  • Correction, read-queue ticket 07 (2026-09-06). The earlier note said the recent-actions index “has no full-text search from the page”. It does: the page carries a form posting search_api_fulltext, ra-start-date, ra-end-date and ra_year back to /recent-actions itself, so https://ofac.treasury.gov/recent-actions?search_api_fulltext=<term>&ra-start-date=MM%2FDD%2FYYYY searches all 3,152 announcements and filters them by date. It is nonsense-controlled - zzzqqxnonsense returns “No results” while China returns 309 - and it indexes designated-entity names, not only titles: Garantex returns 3, Funnull 1, Aeza 4. That closes the “no agent read every designation” limit this item used to carry.
  • The SDN list is downloadable and greppable, which is the stronger route and the one this negative now rests on: https://sanctionslistservice.ofac.treas.gov/api/PublicationPreview/exports/SDN.CSV returns 5.7 MB and 19,329 rows to a plain curl. The program code is column 4 (CYBER2, CMIC-EO13959 and so on) and the remarks column carries the Unified Social Credit Code for Chinese entities.
  • No Evidence is attached because there is nothing in-window to attach. The two Chinese cyber designations that exist are dated 2025-01-03 and 2024-12-10, and the evidence gate refuses anything before 2025-01-20 - correctly, since a pre-window designation is not action on this ask. They are recorded in the note instead.
Action
restrict
Object
Companies facilitating China's Great Firewall
ID
2087