REPORT: Chinese Banks in the EU's Crosshairs — The Vice Tightens on the Enablers
In June 2026, the European Union has never looked more determined to draw a red line around the financial circuits that allow
- In June 2026, the European Union has never looked more determined to draw a red line around the financial circuits that allow
- Introduction: The File Making Beijing Tremble
- A Signal Sent from Brussels
Facts, quotes, and cited links remain in the body. Interpretations are framed as analysis or opinion according to the format.
Introduction: The File Making Beijing Tremble
A Signal Sent from Brussels
In June 2026, the European Union has never looked more determined to draw a red line around the financial circuits that allow Moscow to bypass Western sanctions. On June 9, 2026, European Commission President Ursula von der Leyen unveiled a 21st sanctions package against Russia, the most ambitious since the start of the war. And for the first time on this scale, banks and financial entities from third countries — including China — are explicitly in the crosshairs. This is no longer a warning. It is an action plan.
The scope of this package is unprecedented: asset freezes on nearly 90 banks, additional transaction bans on more than 30 financial institutions in Russia and third countries, and the sidelining of 11 cryptocurrency platforms accused of helping Moscow circumvent financial restrictions. This figure, repeated by EU foreign policy chief Kaja Kallas, resonates like a declaration of financial war against the accomplices of Vladimir Putin.
China at the Heart of the Problem
Behind the diplomatic phrasing, the message is crystal clear. The EU's sanctions envoy, David O'Sullivan, told Euronews in early June 2026 that China remains a "very big problem" for the effectiveness of European restrictions. He bluntly admitted that while Brussels had listed certain Chinese companies and banks in previous packages, and some had agreed to stop financing Russian activities, the problem of sanctions evasion by Beijing remains unresolved. These admissions, coming from a senior European official, measure the scale of the challenge.
This context is not new, but it is taking on an accelerated dimension in the summer of 2026. According to European Commission data and Bloomberg reports, more than 90% of Russian imports of sanctioned technologies, which could be used in weapons production, now transit through China — compared to about 80% in 2025. This is a worrying shift documenting Moscow's growing dependence on Chinese enablers.
The Background: When Bloomberg Broke the Silence
The Report That Changed Everything
Let's go back to June 2025. According to data compiled by the U.S.-China Economic and Security Review Commission (USCC), it was on June 12, 2025, that Bloomberg first revealed the European Union was considering sanctioning two Chinese banks for helping Russia bypass trade restrictions imposed since the invasion of Ukraine. Beijing's reaction was immediate: Foreign Ministry spokesperson Lin Jian stated that China opposed all unilateral sanctions not approved by the UN Security Council, and that exchanges between Chinese and Russian companies complied with World Trade Organization rules.
The formula was well-rehearsed, predictable, and above all, revealing of a line of defense Beijing has used since 2022: denying all complicity by invoking the multilateral framework, while allowing aid circuits for Moscow to thrive. The names of the two targeted banks were not immediately made public, but their presence in the European crosshairs was enough to send a shockwave through Sino-Russian financial circles.
Beijing's Counter-Strike in August 2025
The story didn't end there. Two months after the Bloomberg report, in August 2025, European sanctions against these two Chinese banks — officially for providing "crypto-asset services" to Russia — came into effect. The Chinese response was surgically targeted: the Ministry of Commerce of China announced retaliatory sanctions against two Lithuanian banks, UAB Urbo Bankas and AB Mano Bankas. This choice was no accident: Lithuania is one of the EU member states most determined to support Ukraine and defy Moscow.
This retaliation mechanism says everything about Beijing's strategy: not to submit, but to exert calibrated pressure on the most vulnerable links in the European bloc. By targeting two banks from a modestly sized Baltic country rather than French or German institutions, China sends a message — it can strike — while avoiding a direct escalation with the EU's major economic powers.
The Banking Mechanism: How the Enablers Operate
The Sanctions Circumvention Circuit
To understand why Chinese banks are at the heart of the problem, we must dissect the sanctions circumvention mechanism as it has functioned since 2022. When major Russian banks lost access to the SWIFT system and their assets were frozen by the West, Moscow sought new payment circuits. China, officially neutral but unofficially aligned with Russian interests, quickly filled the void. The Chinese interbank messaging system CIPS (Cross-Border Interbank Payment System) became the preferred alternative.
According to data cited by various financial analyses in 2026, the volume of Russia-China transactions settled via CIPS has seen a spectacular increase since 2022, bypassing the dollar and the SWIFT system in bilateral trade. Second-tier Chinese banks, less exposed to Western markets than major institutions like ICBC or Bank of China — which have themselves reduced their exposure to Russia for fear of U.S. secondary sanctions —, have played the role of intermediaries. These are precisely the actors the EU is now targeting.
The Role of Cryptocurrencies in the Circuit
Parallel to traditional banking transactions, the European Union has documented the increasing use of cryptocurrencies by Russian networks to bypass sanctions. The ruble-backed stablecoin, A7A5, accounted for some $93.3 billion in transactions over ten months, according to Chainalysis. Chinese banks, according to European authorities, provided "crypto-asset services" allowing these flows to circulate off the radar of Western regulators. This is precisely the area where the two Chinese banks sanctioned in August 2025 were caught.
The scale of the phenomenon led the EU to include, in its 20th sanctions package of April 2026, a total sectoral ban on crypto-asset service providers established in Russia, as well as restrictions on the digital ruble and the RUBx stablecoin. The 21st package, proposed on June 9, 2026, goes even further by introducing the possibility of a complete ban on crypto services for entire third countries — an unprecedented weapon that can target any country hosting platforms helping Russia bypass restrictions.
The 21st Package: The Mechanics of an Unprecedented Tightening
The Figures Illustrating the Ambition
On June 9, 2026, the President of the European Commission, Ursula von der Leyen, presented what observers unanimously call the most ambitious package since the conflict began. The numbers speak for themselves: nearly 90 banks targeted by asset freezes, more than 30 financial institutions hit with additional transaction bans in Russia and third countries, 170 individuals and entities added to the sanctions list, and 11 cryptocurrency platforms targeted. If this package is adopted unanimously by the Council of the EU — a goal set for July 15, 2026 —, the total number of Russian banks under sanctions will exceed 100 establishments, which is more than half of the Russian banks connected to the international financial system.
But the decisive novelty of this 21st package lies in its extraterritorial architecture. For the first time on this scale, 20 third-country entities — banks, crypto platforms, oil traders — are targeted for having served sanctioned Russian entities or helped bypass European measures. The list of countries concerned explicitly includes China, Turkey, Kyrgyzstan, Kazakhstan, the United Arab Emirates, and India. It is a precise mapping of the circumvention highways.
The Logic of Progressive Escalation
This 21st package is part of a logic of progressive escalation that the EU has patiently built since 2022. The 19th package of October 2025 constituted a historic first by sanctioning two Chinese refineries and one Chinese oil trader — the first time the EU had targeted non-Russian entities for the purchase of Russian oil. The 20th package of April 2026 further expanded the perimeter with transaction bans covering Russian oil ports and third-country refineries linked to sanctions evasion. Each package widens the circle of potential targets in China.
On a legal level, the instrument is formidably effective: any bank, crypto platform, or refinery on the list faces an immediate asset freeze and an absolute ban for European entities to do business with it, regardless of where it is registered. The extraterritorial reach is calculated to strike where it hurts: access to the European financial system, European companies, and the markets of the old continent.
The Mini-Package of June 15, 2026: Concrete Action
Chinese Entities Directly Targeted
Parallel to the negotiations on the major 21st package, the EU took an extra step on June 15, 2026. That day, the Council of the EU adopted a "mini-package" of sanctions, published under implementing regulation (EU) 2026/1361, directly targeting several entities from Belarus, China, Azerbaijan, and Hong Kong. Among the identified targets is Shenzhen Minghuaxin, a Chinese company documented by the analysis platform Kharon for having made nearly 400 shipments of technology and equipment to Rustakt LLC, a Russian drone manufacturer now itself sanctioned by the EU and Canada. Its declared majority shareholder, Wang Dinghua, also held a stake in Rustakt.
This sanction is emblematic of the operating mode the EU seeks to dismantle: a Chinese tech company providing electronic components to a Russian drone manufacturer, which produces weaponry deployed on the Ukrainian battlefield. The causal chain is direct. The Kharon report published on June 17, 2026, also specifies that the EU was studying information that Chinese military personnel may have trained Russian soldiers to fight in Ukraine — an allegation of extreme gravity if it were to be confirmed.
The Symbolic and Diplomatic Reach of the Mini-Package
Beyond its technical content, this June 15, 2026, mini-package carries considerable symbolic weight. It demonstrates that the EU is no longer satisfied with warnings or statements of principle: it is listing names, freezing assets, and imposing trade restrictions on concrete Chinese entities. Regulation (EU) 2026/1361 also adds twelve establishments based in Azerbaijan and Hong Kong to the list of sanctioned entities for their role in supporting the Russian war effort — illustrating the growing geographical scope of European pressure.
On the London side, a similar logic is at work. The same week, the United Kingdom announced new sanctions against four Chinese companies for providing military equipment to Russia, prompting a formal protest from the Chinese Embassy in London. These coordinated EU-UK actions testify to a convergence of views between Brussels and its partners on the need to target Chinese enablers.
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Beijing's Reaction: Law as a Shield
He Lifeng and the Anti-Sanctions Legal Arsenal
While the EU tightens the vice, Beijing is not sitting idly by. On June 17, 2026, at the Lujiazui Forum in Shanghai, Chinese Vice Premier He Lifeng announced that China would write anti-sanctions provisions directly into its financial laws. According to a Bloomberg article dated the same day, He Lifeng promised to counter what he calls "unreasonable foreign suppression," asserting that the financial law project would contain explicit provisions to block and counter sanctions imposed from the outside. This is not a policy signal or an administrative circular: it is a legal weapon written into national law.
The scope of this announcement is staggering for international financial actors. If Chinese law makes it legally dangerous for a foreign bank to comply with Western sanctions targeting Chinese entities, European and American institutions find themselves caught in a vice between two contradictory legal systems. A European bank freezing the assets of a Chinese entity sanctioned by the EU could thus find itself in violation of Chinese law. This is precisely the trap Beijing is trying to set.
The Strategy of Legal Immunity
This legal strategy of counter-sanctions is part of a broader movement initiated several years ago. Blocking Order No. 21 of 2026 from the Chinese Ministry of Commerce, published in May 2026 in response to U.S. sanctions on Chinese petrochemical companies linked to Iranian transactions, constitutes a direct precedent. Beijing systematically uses blocking orders to deter foreign companies from complying with Western sanctions when they target Chinese entities.
In doing so, China no longer denies playing a role in bypassing Russian sanctions — it is building a legal infrastructure to make this role legally defensible on its territory. This strategic evolution, documented by financial analysts at TaxWell & Partners in a June 2026 note, confirms that Beijing has fundamentally abandoned the posture of neutrality to adopt that of a structural co-actor of the alternative financial system Moscow has been building since 2022.
The Role of the CIPS System and Accelerated De-dollarization
The Infrastructure of the Parallel Economy
Understanding the scale of the problem involves taking a close look at the CIPS system, the Chinese alternative to the SWIFT network. Since 2022, this interbank messaging system has become the backbone of Russia-China commercial transactions freed from the dollar. The volumes passing through it have literally exploded since Russia's full-scale invasion of Ukraine. Yuan exchanges between the two countries have also surged: Russia has become one of the main markets for the international use of the renminbi, at Beijing's express request.
Yet, it is precisely this infrastructure — second-tier Chinese banks, yuan settlement platforms, shell companies based in Hong Kong — that European customs services and financial intelligence agencies have identified as the primary vector for sanctions evasion. The Chinese Ministry of Commerce has imposed on foreign companies, via State Council Decree No. 837 of June 2026, a requirement not to export technology, knowledge, or data under the guise of foreign investment — a measure officially aimed at capital outflows but illustrating Beijing's reinforced control over its financial circuits.
Chinese Banks Between Two Fires
The situation of major Chinese banks is paradoxical. ICBC, Agricultural Bank of China, and China Construction Bank have significantly reduced or even suspended their payment services to Russian counterparties since late 2023, precisely for fear of U.S. secondary sanctions — which can cut a foreign bank off from access to the dollar if it deals with sanctioned entities. But smaller institutions, less dependent on the U.S. market, have taken over. Bank of China Russia and certain regional Chinese banks have maintained flows with Russia, according to TaxWell & Partners analysts in their June 2026 note on yuan payments in Russia.
This double movement — larger banks retracting, smaller ones taking over — illustrates the extreme agility of the circumvention network that Moscow has set up with the help of its Chinese partners. The EU is well aware of this, which is why the 21st package targets 20 third-country financial entities rather than sticking only to Russian institutions.
The Diplomacy of Sanctions: Envoy O'Sullivan vs. Beijing
A Dialogue of the Deaf
Since his appointment, the EU's sanctions envoy, David O'Sullivan, has been leading an intense diplomatic dialogue with Chinese authorities to try to convince them to cooperate on applying the restrictions imposed on Russia. In an interview with Euronews in early June 2026, O'Sullivan gave a mixed assessment: yes, some Chinese banks agreed to cease their cooperation with Moscow after being threatened with sanctions. No, China as a whole is not playing the game and remains a "very big problem."
This carrot-and-stick diplomacy has its structural limits. The EU cannot sanction China as a whole without provoking an economic crisis whose effects would rebound on its own companies and consumers. Bilateral EU-China trade represents hundreds of billions of euros annually. Therefore, Brussels is walking on eggshells: targeting specific Chinese entities, by name and with evidence, while avoiding inflaming a commercial relationship on which Europe still largely depends for its industrial imports.
The Limits of Diplomatic Pressure
Diplomatic exchanges between the EU and China on the sanctions issue run into a fundamental obstacle: Beijing contests the legal legitimacy of unilateral Western sanctions. The official position, tirelessly repeated by Foreign Ministry spokespeople, is that only UN Security Council sanctions are legitimate — a body in which China holds a veto that it systematically uses to protect Russia. This posture makes any binding agreement structurally impossible.
This realization does not stop the EU from acting unilaterally — which is precisely what it is doing with the 21st package and the June 15, 2026, mini-package. But it explains why O'Sullivan asserted that unilateral actions against Chinese companies and financial institutions will remain necessary. Diplomacy has its virtues, but it is not enough when faced with a partner that has decided that contesting international law serves its interests better than respecting it.
Progression by Packages: A Staircase Architecture
From Exception to Rule
The trajectory of the 21 European sanctions packages against Russia illustrates a major doctrinal shift: from sanctioning only Russian actors to sanctioning the entire ecosystem that feeds Moscow's war machine. The 19th package of October 2025 constituted a historic turning point by being the first to sanction non-Russian entities — two Chinese refineries and one Chinese oil trader — for purchasing Russian oil sold in violation of Western restrictions. What was an exception is becoming a rule.
The 20th package of April 2026 deepened this logic by imposing transaction restrictions covering Russian oil ports and third-country refineries linked to sanctions evasion. It also introduced a total sectoral ban on crypto-asset service providers established in Russia or Belarus, as well as restrictions on the digital ruble and the RUBx stablecoin — measures that implicitly targeted the crypto financial circuits through which Chinese actors transited Russian funds.
Widening the Target Perimeter
The Kiel Institute for the World Economy report commenting on the presentation of the 21st package emphasizes that despite four years of war and twenty sanctions packages, trade between Russia and certain third countries — including China — has not significantly decreased. The conclusion is final: sanctions on Russian actors alone are insufficient if external enablers are not also targeted. This is exactly the logic underlying the 21st package.
The Council of the EU must adopt this package unanimously, meaning each member state has a veto. Member countries with significant trade links to China or India might be tempted to temper the most aggressive measures. The July 15, 2026, deadline is linked not to the Chinese file but to the question of capping the price of Russian oil — illustrating the complexity of ongoing negotiations within the Council.
The Oil Stake: The Price Cap and its Circumvention
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The Price Cap Mechanism Under Pressure
One of the central tools of the sanctions regime against Russia is the Russian oil price cap implemented by the G7 and the EU. This mechanism prohibits Western insurance and shipping companies from assisting operations involving Russian oil sold above a price cap, set at approximately $44 per barrel until January 2027 according to the 21st package proposal. The goal is to reduce the oil revenue Moscow uses to finance its war in Ukraine.
But the device is structurally vulnerable to circumvention. The ghost fleet — a network of aging tankers, often registered under flags of convenience and insured by non-Western companies — transports an increasing share of Russian oil outside Western-controlled circuits. Chinese entities, according to investigations by the OCCRP and other organizations, are among the actors facilitating these off-the-radar transport and insurance operations. The 21st package provides for sanctions on ports, airports, and refineries that handle this oil — a measure directly targeting transit hubs in third countries, including China.
Chinese Refineries in the Supply Chain
The sanctioning of two Chinese refineries in the 19th package of October 2025 sent a strong signal: these facilities were buying Russian oil sold above the authorized cap, actively participating in a mechanism that deprived the price cap system of any effectiveness. The Hudson Institute, in a May 2026 analysis, points out that the sanctions of the Trump administration innovated by allowing for the first time sanctions against buyers of Russian oil and the banks financing those transactions — including those based in China, Hong Kong, and India. A partial alignment of American and European practices thus reinforces the overall effectiveness of the regime.
According to data compiled by Bloomberg and cited by the USCC, more than 90% of Russian imports of sanctioned technologies pass through China as of mid-2026 — compared to 80% in 2025. This figure illustrates a growing dependence of Moscow on Beijing, but also a scale-up of financial flows financing these purchases. Every ruble of technology imported via China is a breath of oxygen for the Russian military-industrial industry that kills Ukrainian soldiers and civilians.
Alternative Payment Networks: Shadow Finance
Intermediaries in the Shadows
The OCCRP investigation published on June 17, 2026, titled "There Will Be No Trace," lifts the veil on a well-oiled machine: Russian payment agents operating via Telegram offer their services to companies seeking to bypass financial restrictions. These intermediaries boast of their mastery of cryptocurrencies, notably the A7A5 stablecoin, and their ability to use companies in Hong Kong to issue invoices that mask the Russian origin of the payments.
This shadow finance network illustrates how sanctions are bypassed not by major banks — which are too visible and too dependent on Western markets — but by a dense ecosystem of small actors, shell companies, and crypto platforms. The role of entities based in Hong Kong is particularly well-documented: as an international financial center under Chinese sovereignty, Hong Kong offers a unique point of access to Western financial systems while benefiting from Beijing's political protection.
The A7A5 Case and Decentralized Finance Serving Moscow
The A7A5 stablecoin deserves special attention. Launched by the company A7 belonging to Russo-Moldovan oligarch Ilan Shor — now himself under European and British sanctions — in partnership with Promsvyazbank, a Russian state bank supporting the military-industrial complex, A7A5 is used according to its own communications in nearly 20% of Russian international transactions. With more than 44 billion tokens issued as of May 15, 2026, it represents a market value of over $600 million.
The EU has targeted platforms trading A7A5 since the 19th package, and the 20th package expanded these restrictions. The 21st package provides the possibility to totally ban crypto services for entire countries that host platforms facilitating the circumvention of Russian sanctions — a regulatory nuclear weapon that could apply to Chinese jurisdictions if they persist in sheltering these operations.
The American Position: Trump, Secondary Sanctions, and China
The Unexpected Convergence with Washington
In this picture, the position of the Trump administration deserves notice. Contrary to what some feared after his return to the White House, Washington has maintained significant pressure on Moscow's financial enablers. According to an analysis by the Hudson Institute published in May 2026, the new Trump sanctions on Russia have innovated on one crucial point: they allow for the first time sanctions against buyers of Russian oil and the banks financing those transactions, including those based in China, Hong Kong, and India. This is a significant extension of the extraterritorial reach of U.S. sanctions.
Major Chinese banks like ICBC, Agricultural Bank of China, and China Construction Bank have reduced their exposure to Russia since late 2023 precisely for fear of U.S. secondary sanctions — which can cut them off from access to the U.S. dollar, representing a death sentence for any financial institution with international ambitions. This American threat has had a real deterrent effect on the largest Chinese banks, even if smaller ones have taken the baton.
G7 Coordination: A Multiplier Lever
At the G7 summit held in June 2026, leaders pledged to "increase pressure on the Russian war economy," notably by strengthening sanctions on its oil and gas sectors. This collective statement, covering the U.S., the EU, and the UK, reinforces the global architecture of the sanctions regime. According to Kharon, G7 leaders explicitly linked this decision to the geopolitical context of the Strait of Hormuz, stating that "this is the right time to take additional measures" — a phrasing suggesting that economic pressure on Moscow is deliberately coordinated with other global geopolitical dynamics.
This international coordination is a precious asset for the EU in its standoff with Chinese enablers. When Europe, the United States, and the United Kingdom speak with one voice — with converging measures targeting the same circumvention circuits — the pressure on hesitant Chinese banks becomes much harder to ignore. The Chinese financial entity weighing the risks of its relations with Russia faces not just one jurisdiction but a coordinated bloc that controls access to the world's main markets and reserve currencies.
Ukraine at the End of the Chain: Reality on the Ground
What These Figures Mean for Kyiv
We must constantly remember why all this matters. Every Russian drone that strikes Kyiv, Kharkiv, or Odesa is assembled with electronic components, the overwhelming majority of which transit through China. Every Russian ballistic missile integrates semiconductors that, in many cases, were legally exported from Chinese companies to Russian intermediaries by bypassing export restrictions. The link between the financial circuits the EU seeks to dismantle and the reality of the war in Ukraine is not metaphorical — it is direct, documented, and measured in human lives.
The Ukrainian government, on the front lines of this reality, closely follows the discussions on European sanctions against Chinese enablers. Kyiv has explicitly asked its Western partners to intensify pressure on Beijing, considering that without cutting off Sino-Russian logistical and financial circuits, Moscow's war effort cannot be durably weakened. Volodymyr Zelenskyy has reminded many times that the war is also won in the meeting rooms of Finance and Foreign Affairs ministries, not just on the battlefields.
Ukrainian Resistance Against a Machine Funded from Outside
The remarkable resilience of the Ukrainian army since 2022 has been possible thanks to Western support in weaponry, ammunition, and funding. But this support effort runs into a cruel reality: while the West helps Ukraine, China helps Russia. Not openly, not with soldiers — at least so far — but with electronic components, financial circuits, crypto platforms, and second-tier banks that fuel the Russian military-industrial machine.
The EU's growing pressure on Chinese banks and financial entities that facilitate sanctions evasion is therefore direct aid to Ukraine, even if it is exercised thousands of miles from the front. Every Chinese entity sanctioned, every financial circuit disrupted, every transaction blocked is an additional obstacle on Moscow's road to rearmament. It is an economic war doubling a military war — and the EU has finally decided to fight it seriously.
Conclusion: The Financial War is Not Over
A Vice That is Tightening, Not Yet Closed
The European Union crossed a qualitative threshold in June 2026 in its financial war against the circuits that allow Russia to maintain its war effort in Ukraine. The 21st sanctions package, proposed on June 9, the mini-package of June 15 targeting concrete Chinese entities like Shenzhen Minghuaxin, and the rigorous documentation of banking and crypto circumvention mechanisms — all of this constitutes a regulatory arsenal of unprecedented scope. The mechanics of extraterritorial sanctions, long reserved for the United States, are now fully embraced by Brussels.
But the vice is not yet closed. The 21st package must be adopted unanimously by the Council of the EU before July 15, 2026, and diplomatic negotiations are still ongoing. Beijing, for its part, is not staying passive: the announcement by He Lifeng on June 17, 2026, of writing anti-sanctions provisions into Chinese financial law illustrates that China has decided to play in the same court as the West — but with its own rules. The financial war around Russia is far from over.
The Long-Term Strategic Stake
Behind the Chinese banks and sanctions file, something more fundamental is playing out: the question of whether the international financial order built around the dollar, the euro, and the SWIFT system can resist a coalition of states — Russia, China, Iran, North Korea — seeking to build another. The European sanctions against Chinese enablers are not just a response to the war in Ukraine: they are a defense of the multilateral financial regulation model that guarantees the stability and predictability of world trade.
If Brussels weakens, if the Council of the EU dilutes the 21st package under pressure from its most hesitant members, if sanctions against Chinese entities remain symbolic rather than systematic, the message sent will be disastrous: that the EU can be intimidated by Beijing, that Moscow's circumvention circuits are impenetrable, and that the war in Ukraine can be funded indefinitely from entities located out of reach of the West. This scenario is unacceptable. The vice must close — and fast.
Signed Maxime Marquette, columnist
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Cite this article
Maxime Marquette (2026). REPORT: Chinese Banks in the EU's Crosshairs — The Vice Tightens on the Enablers. MadMax. https://mad-max.co/en/article/reportage-banques-chinoises-dans-le-viseur-de-l-ue-l-etau-se-resserre-sur-les-fa-2
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