US-China Economic and Security Review Commission Staff Warn Against CCP LOGINK | Holland & Hart – International Compliance Blog

Companies, US and non-US, that contract with the US government would do well to carefully read and evaluate the recent September 20 advisory issued by staff of the US Economic and Security Review Commission -Chinese. Commission staff posted an “information note” or notice on China’s National Transportation and Logistics Public Information Platform for Logistics Data Transmission (aka LOGINK). This notice can be found here LOGINK: Risks of China’s Promotion of a Global Logistics Management Platform (

As described by Commission staff, “LOGINK provides users with a one-stop shop for logistics data management, shipment tracking and information exchange needs between businesses as well as between businesses and government. The Chinese government encourages global ports, cargo carriers and freight forwarders, as well as other countries and entities to adopt LOGINK by providing it free of charge. Although LOGINK is not an issue in 90% of a company’s international sourcing and selling efforts, one can well imagine that international shipments to, via or from certain parts of the world may cross ports, carriers of freight and freight forwarders who employ LOGINK from China.

The Commission services warn against the adoption of LOGINK, both for the security of confidential information and commercial secrets of individual companies and for the future of economies based on the protection of free trade and civil liberties. The September 20 notice notes the following:

“The widespread adoption of LOGINK could create economic and strategic risks for the United States and other countries. As with other government-sponsored or subsidized Chinese entities, LOGINK could undermine American companies that provide more innovative products at higher costs without state support. LOGINK’s visibility into global shipping and supply chains could also allow the Chinese government to identify US supply chain vulnerabilities and track US military cargo shipments on commercial cargo. Although LOGINK says users can only share the data they want, the security of the platform is unclear. The Chinese Communist Party (CCP) could potentially access and control huge amounts of sensitive foreign corporate and government data via LOGINK. Notice on page 3.

At this point, unfortunately, there are more questions than answers.

That said, it can reasonably be expected that the Commission staff opinion of September 20 will not be the last word on this subject. It would reasonably be expected that the legislative and executive branches of the US government would add additional advisory information or mandatory guidance in the near future. Therefore, a company may be advised to proceed with caution regarding LOGINK, especially those contracting with the US government. In addition and to the extent that it has not already been undertaken, a prudent business may be advised to undertake an investigation to determine whether LOGINK is already being actively used by ports, cargo carriers or freight forwarders affected by its operations. .

Aurora J. William