The structure of the lists in the draft law shows how diverse the geography of global trade in Russian energy resources is. For oil, the list mainly includes countries that buy raw materials for their own processing or transit. With regard to gas, there is a completely different set of states, including the EU countries, which formally support the sanctions policy against Russia, but continue to purchase Russian gas under separate contracts.
China is the only intersection of these two sets. At the same time, the country remains the largest buyer of Russian oil in Asia and a significant importer of Russian gas, primarily piped through the eastern direction and, in the future, through the Power of Siberia—2 project.
A double mention does not automatically mean a doubled duty — the bill gives the US president the right to apply measures selectively at his discretion, rather than triggering a mechanism for summing up sanctions for each item on the list. But from a political point of view, it is China that becomes the most obvious target if the administration decides to demonstrate determination through the use of new powers.
For companies operating through Chinese banks, logistics intermediaries, or settlement platforms for trading with Russia, China's status as a priority target means it is more likely that Chinese financial institutions will be the first to face increased scrutiny from U.S. regulators if the bill is passed and applied.
China's own reaction to such initiatives has historically been restrained publicly, but practical internally — large Chinese banks usually preemptively tighten compliance procedures for transactions with Russian counterparties long before the actual imposition of sanctions in order to minimize their own risks of secondary restrictions from the United States. For Russian companies using the Chinese settlement circuit, this means a possible increase in payment checks and a longer review of transactions in the coming weeks, regardless of the outcome of the Congressional vote.
