I imagine that it will somehow turn out to be a “private company” in China that’s cooperating, rather than an official gov’t organ. Already the gov’t is saying it’s unaware of this project, so…

So yes sanctions will apply to the “companies” that are involved (which are basically fly by night, or spring up once to do this and then fold themselves). More usefully, some individuals might get named and sanctioned. And finally there’ll be a new talking point in negotiations with China in getting greater cooperation to reign in some of these private companies.

Not saying we shouldn’t try to sanction them. But it’s also worth being mindful of the challenges ahead.