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Chinese authorities announced in late September that Michael Chan, a senior executive at the U.S. risk advisory firm Kroll, had been barred from leaving mainland China since July. Chan, who holds a Hong Kong passport, has not had his movements within mainland China restricted. Chan’s exit ban is reportedly related to a Chinese law enforcement investigation–focused neither on Chan nor the company he works for–with which Chan is cooperating. 

Chan’s exit ban comes on the heels of Charles Wang Zhonghe, a senior investment banking executive at Japanese financial firm Nomura, announcing that he has received an exit ban from mainland China in connection with a similar law enforcement investigation. 

Citing the “arbitrar[y] enforce[ment of] local laws, including . . . exit bans on U.S. citizens and citizens of other countries, without fair and transparent process under the law,” the U.S. Department of State has warned that the “risk of wrongful detention of U.S. nationals” exists in mainland China. As a result, State Department authorities have raised the travel advisory on mainland China to Level 3 (“Reconsider Travel”).


It is unclear whether or not the exit bans on senior executives of foreign firms are connected to the Chinese government’s previous raids on foreign firms, including Bain & Company and Mintz Group. However, these exit bans do show an increasingly volatile environment for U.S. businesses operating in China, especially in light of the changing status of foreign firms as the Chinese economy continues to struggle in its recovery from the coronavirus pandemic.

Foreign businesses in Hong Kong and China, as well as their employees, are now frequently subject to arbitrary or politically motivated law enforcement actions, necessitating a reassessment of corporate best practices in these regions. In order to protect the safety of their employees, foreign companies operating in Hong Kong and mainland China need to develop a new set of compliance and corporate best practices tailored to new political realities under the CCP.Additionally, Chinese authorities have a history of applying harsh exit bans and other such law enforcement measures against both Chinese citizens and foreign nationals on the basis of spurious complaints to police, creating risks to foreign businessmen independent of the broader geopolitical situation.



As Hong Kong is seeing a devastating increase in political persecution, we will continue to pave the way to a free Hong Kong.

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