Case Studies
For privacy and security considerations, this brief does not disclose any personal experiences shared by workshop participants. Instead, several salient public cases illustrate the broader pattern of how young human rights activists are targeted by the CCP within the European Union:
2026: Coercion Below the Criminal Threshold
In January 2026, a man claiming to be a government official from Urumchi contacted Paris-based Uyghur activist Mirkamil Tutghun and ordered him to stop his activism. The caller presented disengagement from activism as a safe pathway towards being reunited with his family in China.5 The same caller had reportedly pressured another Uyghur activist, Abdurahman Tohti, to monitor activities at the European Uyghur Institute6, a leading Uyghur advocacy organization based in Paris. The institute’s founder, Dilnur Reyhan, had previously faced repeated government harassment, including a PRC embassy-initiated complaint to a court in Paris for Dilnur’s participation in a protest, which resulted in a conviction and a small fine7. Informal calls of this kind — from individuals claiming to be government officials, or even family members in China — can easily fall under the criminal threshold in the absence of overt physical violence or explicit threats.
Mirkamil’s case reflects the experience of many Uyghur youth in the diaspora who are unable to return home or maintain ordinary contact with their immediate families left behind. Using this family connection, the PRC’s TNR operates as a deniable instrument of recruitment, surveillance, information extraction, and behavioral control, directly chilling association, expression, and community life in European jurisdictions.
The embassy-initiated proceeding against Dilnur then extends the pattern through lawfare: when a foreign authoritarian state triggers the host country’s own legal system against a diaspora advocate for public-interest protest, the process itself can impose psychological, financial, and reputational costs that chill political expression. Therefore, the procedural validity of the complaint does not exhaust the TNR context; the embassy’s role, the political nature of the expression, and the broader pattern of China’s pressure should inform any assessment of proportionality and chilling effect.
2025: Tara’s Cost of Going Home
In July 2025, Zhang Yadi (“Tara”), a Chinese student who studied abroad in France and advocated for Tibetan rights, was arrested after returning to China while attempting to enter Tibet. She faces charges of “inciting others to split the country and undermine national unity,” with a possible sentence of up to five years, or up to fifteen if treated as a ringleader.8 Her case illuminates a distinct return-risk dimension to China’s TNR. Although Tara’s pro-Tibet activism primarily took place overseas, the Chinese government still viewed her conduct as illegal and punishable. Her arrest aims to send a deterrent message directed at Chinese students and activists abroad: that lawful and protected peaceful advocacy in Europe can be retroactively punished once the individual re-enters China’s jurisdiction.
The concerning implications of the Chinese government’s control and intimidation of activists overseas are further amplified by the newly enacted PRC Ethnic Unity and Progress Law9, which includes provisions that essentially criminalize ethnic-rights advocacy abroad. By providing a legal basis to penalize overseas advocacy, the law creates a chilling effect on freedoms by effectively requiring ideological conformity abroad in order to safely return home to China. Cases of this kind should be treated as an early warning indicator of China’s TNR, and the location where enforcement occurs should not negate the effect of TNR but rather raise policy duties for host governments to provide proactive protection before arrest.
2024: Returning "Voluntarily"
In 2024, Ling Huazhan, a Chinese dissident and lawful refugee based in France, was targeted in an attempted forced repatriation to China. The incident was reportedly carried out by seven individuals, including the head of the Paris office of China’s Ministry of State Security10, and framed under a consular-protection narrative, invoking Ling’s alleged psychological vulnerability to package the coercive nature as assistance.11
Through Operation Fox Hunt and Sky Net, the PRC has often coerced overseas targets to “voluntarily” return home to China by weaponizing family members to exert pressure and “persuasion” on them.12 China’s attempt to physically kidnap a lawful refugee without judicial review or non-refoulement safeguards is one of the extreme methods that the Chinese government deploys. It violates individual liberties and the right to security, overrides France’s territorial jurisdiction, and contravenes international human rights, refugee, and criminal law. For host states, such incidents engage positive obligations to protect individuals within their jurisdiction from TNR, contextually investigate, and take reasonable measures to prevent the forced return or other forms of complicity from happening.
2022 Onwards: Attempts to Censor Teacher Li
Since 2022, Italy-based Chinese activist and influencer Li Ying has been subjected to the full spectrum of TNR — including deepfakes, doxxing, death threats, targeted vandalism, restriction of his financial accounts, as well as sustained coercion of his family and followers inside China.13 Tweeting under the pseudonym “Teacher Li is not your teacher,” Li Ying rose to prominence during the 2022 White Paper protests by posting firsthand videos, images, and testimonies anonymously submitted by Chinese citizens. His account was described as “the central hub of China protest information,” making him one of the most visible overseas Chinese-language sources of uncensored information on events inside China.14
Li Ying’s experience exposes how China’s TNR methods also aim to attack on the transnational information infrastructure that makes dissent possible. The Chinese government targeted Li Ying because he was a high-profile information node through which dissent was amplified, sustained, and transmitted faster than it could be censored. China’s response, therefore, was aimed at disabling the ecosystem that sustained this information flow: his followers and sources inside China, family, friends and associates, financial channels, digital accounts, physical location, reputation, and his social circle in Italy, all operating simultaneously and at scale. Italy later expelled eight Chinese nationals involved in his persecution, demonstrating that host states can act against TNR. Yet the intervention came only after years of cumulative harm that individuals like Li Ying personally bore until the host state’s response became possible.
2021: When A Democracy Enables TNR
In 2021, Greek police arrested Tibetan student Tsela Zoksang and Hong Kong activist Joey Siu after a peaceful protest in Acropolis to boycott the 2022 Beijing Winter Olympics.15 Police also detained Tibetan-Canadian activist Chemi Lhamo, Free Tibet’s Jason Leith, and activist Fern MacDougal for shouting slogans and holding a “No Genocide Games” banner — actions which Greek officials claimed to be “violating the law on protection of archaeological sites” — at the torch lighting ceremony. The activists’ lawyers asserted the charges were unfounded and constituted a breach of the activists’ rights to freedoms of assembly, expression, thought, and conscience under the European Convention on Human Rights.16 Through the duration of the activists’ peaceful advocacy campaign in Greece, credible sources reported Chinese embassy-linked surveillance, intimidation, and pressure on Greek police leading up to their detention.17
Regardless of whether Greek officials indeed acted in direct response to CCP pressure, their actions were successful in amplifying the Chinese government’s desire to coerce and censor advocates overseas. This case reveals how local structural receptivity, potential weaknesses in rule-of-law mechanisms, and strong incentives to avoid offending Beijing may make a member state’s law enforcement an inadvertent force multiplier for TNR. This remains an ongoing problem, where local authorities often lack understanding of TNR, leaving victims to navigate systems alone.
Some of the aforementioned cases prompted intervention by local authorities, reflecting a broader trend of the EU’s rising engagement on TNR, marked by secret police station closures18, proxy expulsions19, parliamentary resolutions20, and the June 2025 G7 Leaders’ Statement.21
However, current EU responses tend to primarily follow high-profile cases — such as PRC attempts to forcibly return individuals to China or instances where the victim has engaged in public advocacy — rather than proactively recognizing early signs and preventing them.
The Chinese government has long been able to incentivize and pressure individuals, institutions, and even foreign governments into supporting repression.22 At the same time, the CCP’s tactics are also evolving quickly. AI-powered repression has enabled an increasing shift towards proxies or pro-regime entities instead of formal state agents.23
The reactive nature of responses from democratic governments, along with the rapidly expanding repertoire of China’s TNR tactics, leaves a window open for harm to be consolidated before it is classified as actionable. Rights advocates and diaspora communities are often left to navigate such coercion alone. This burden is especially difficult for individuals outside NGOs, advocacy or academic networks, due to fears of retaliation, a lack of awareness of local law enforcement, and the absence of trauma-informed reporting channels. EU government institutions should first offer substantial support, confidentiality, and clear pathways to protection before encouraging victims to report their personal experiences of TNR.
Without an official, comprehensive, and internationally-recognized definition of TNR, dedicated resources, trained frontline personnel, and community-informed referral pathways, European systems risk continuing to underrecognize TNR, respond too late, or, in some cases, inadvertently become conduits for the very repression they seek to prevent.
Recommendations
Building on the gaps identified and reflecting on recurring concerns raised by young activists and experts across communities, European institutions should consider the following:
- Establish an EU-wide working definition of transnational repression that recognizes TNR as a violation of rights protected under the European Convention of Human Rights, and in its severity and systematic nature, may constitute a crime against humanity within the meaning of Article 7 of the Rome Statute of the International Criminal Court.24 The understanding should situate TNR as part of broader patterns of foreign interference that weaken democratic institutions and the rule of law, while making clear that it cannot be reduced to a security issue alone. The definition should center on the unique vulnerabilities and lived experiences of diaspora and exiled communities with a national connection to the origin government. Lastly, the existence of such a definition should be well-informed across departments, and create positive obligations for Member States to proactively protect affected communities with effective policy responses.
- Incorporate TNR-sensitive risk assessments into visa, residency, asylum, and extradition decisions to ensure EU migration and cross-border enforcement does not inadvertently facilitate or expose individuals to TNR.
- The EU migration and asylum frameworks should treat TNR indicators themselves as amounting to persecution of the kind asylum law is designed to protect. Return travel, citizenship status, or the absence of physical harm, should not, on its own, be treated as sufficient to rebut a person’s claimed risk of persecution, or to justify rejecting asylum, deporting, or extraditing an individual.
- EU authorities should conduct a contextual review of terrorism, fraud, corruption, or national security allegations advanced by origin states against individuals and diaspora organizations, recognizing that such labels may themselves be instruments of repression.
- EU institutions should equally scrutinize cases in which third countries facilitate the forced return of such individuals or groups to China.
- To the best of their abilities, EU Member States should explore avenues to extend protective measures to victims’ family members abroad, through diplomatic engagements to reduce exposure to coercion-by-proxy or reprisals.
- EU Member States should strengthen visa and residence-permit screening, revoke or refuse status for individuals credibly complicit in perpetrating TNR, in order to prevent perpetrators and enablers from acquiring EU residency rights that facilitate illicit activity.
- The EU migration and asylum frameworks should treat TNR indicators themselves as amounting to persecution of the kind asylum law is designed to protect. Return travel, citizenship status, or the absence of physical harm, should not, on its own, be treated as sufficient to rebut a person’s claimed risk of persecution, or to justify rejecting asylum, deporting, or extraditing an individual.
- Strengthen EU-level safeguards against potential misuse of Interpol notices for transnational repression. EU institutions, in collaboration with Member States, should undertake an independent assessment of the risk of transnational repression before acting on a Red Notice issued by States with documented patterns of politically-motivated misuse. The EU Member States, in cooperation with like-minded partners, should advocate to seek accountability for repeat offenders. EU institutions should institute detailed reporting on Interpol abuse and develop strategies to prevent further instrumentalization of Interpol as a tool of TNR.
- Build frontline capacity for TNR reporting, monitoring, and response. European institutions should prioritize allocating resources to:
- Establish trauma-informed, multilingual, and accessible reporting channels that ensure data protection and confidentiality. The information reported should be assessed fast with immediate and individualized follow-up support, investigation, and protection measures.
- Create a community-rooted TNR database to map emerging tactics and risks, assess patterns to maintain ongoing community experience-based knowledge production and effective information sharing amongst Member States and government agencies.
- Increase training of relevant personnel who interact with victims and/or are involved in the prevention, detection, investigation, and prosecution of TNR, including but not limited to local police, migration officers, social workers, journalists, and school staff.
- Support ongoing awareness-raising campaigns across all sectors, including academia, media, law enforcement, and civil society.
- Increase sustained engagement with diaspora members and organizations as partners in knowledge production and policy design, rather than only as consultees after harm has occurred.
Formally define digital transnational repression and AI-enabled censorship and incorporate them within the scope of systemic risk covered by the Digital Services Act (DSA) to hold digital platforms accountable for targeting exiles. Major technology companies and other private actors should be held accountable for facilitating TNR, establish priority reporting and rapid response channels for victims, and provide effective remedies against coordinated abuse, account compromise, and politically-motivated takedowns.
References
“Transnational Repression,” Civic Space Brief, United Nations Office of the High Commissioner, https://www.ohchr.org/sites/default/files/documents/publications/transnational-repression-1-en.pdf.
TNR breaches various rights protected under, inter alia, the UN Charter, the Universal Declaration of Human Rights, the International Covenant on Civil and Political Rights, the Rome Statute, and the Refugee Convention.
Freedom House, “Collaboration and Resistance: Tracking Transnational Repression in 2025,” April 2026, https://freedomhouse.org/report/special-report/2026/collaboration-and-resistance-tracking-transnational-repression-2025.
Human Rights Foundation, “Beyond Borders: HRF Equips Young Leaders With Skills to Counter China’s Transnational Repression,” April 2026, https://hrf.org/latest/beyond-borders-hrf-equips-young-leaders-with-skills-to-counter-chinas-transnational-repression/.
Arslan Hidayat, Nur Iman, “Chinese Officer Offers Uyghur A Way Out,” February 2026, Kashgar Time, https://kashgartimes.substack.com/p/chinese-officer-offers-uyghur-a-way.
Human Rights Watch, “China: Officials Pressuring Uyghurs in France,” February 2026, https://www.hrw.org/news/2026/02/18/china-officials-pressuring-uyghurs-in-france.
Human Rights Watch, “Uyghur Scholar-Activist Faces Charges in France for Criticizing Beijing,” October 2025, https://www.hrw.org/news/2025/10/09/uyghur-scholar-activist-faces-charges-in-france-for-criticizing-beijing.
Amnesty International, “China: Young student targeted for peaceful activism abroad: Zhang Yadi,” ASA 17/0349/2025, October 2025, https://www.amnesty.org/en/documents/asa17/0349/2025/en/.
European Parliament Delegation for Relations with the People’s Republic of China, “New Chinese Law on Ethnic Unity and Progress,” May 2026, https://www.europarl.europa.eu/delegations/en/new-chinese-law-on-ethnic-unity-and-prog/product-details/20260502DPU41892.
Jacques Follorou, “France Asks Two Chinese Spies to Leave After Attempt to Forcibly Repatriate Man,” Le Monde, Updated July 2024, https://www.lemonde.fr/en/france/article/2024/07/03/france-asks-two-chinese-spies-to-leave-after-attempt-to-forcibly-repatriate-man_6676591_7.html.
Embassy of the People’s Republic of China in France, “Déclaration de l’Ambassade de Chine en France,” May 2024, https://fr.china-embassy.gov.cn/fra/zfzj/202405/t20240502_11292331.htm?utm.
Safeguard Defenders, “Involuntary Returns: China’s Covert Operation to Force “Fugitives” Overseas Back Home,” January 2022, https://safeguarddefenders.com/sites/default/files/pdf/INvoluntary%20Returns.pdfbankaaccount.
“Teacher Li: The Full Transnational Repression Story,” Safeguard Defenders, May 2024, https://safeguarddefenders.com/en/blog/teacher-li-full-transnational-repression-story.
“Teacher Li: The Full Transnational Repression Story,” Safeguard Defenders, May 2024, https://safeguarddefenders.com/en/blog/teacher-li-full-transnational-repression-story.
Cornelius Dieckmann, “‘Teacher Li’: Catching Up with the Most Effective Chinese Regime Opponent,” Der Spiegel International, June 2025, https://www.spiegel.de/international/world/teacher-li-catching-up-with-the-most-effective-chinese-regime-opponent-a-1f4c11bc-4ba8-4f07-862d-c5705af3e1ab https://www.technologyreview.com/2022/12/02/1064075/teacher-li-twitter-china-protests/
King Man Ho, “Tibetan, Hong Kong Activists Detained by Greek Police After Acropolis Olympics Protest”, Radio Free Asia, October 2021, https://www.rfa.org/english/news/china/china-olympics-10182021141310.html.
Students for Free Tibet, “Human Rights Activists Face Legal Battle In Greek Courts Following “No Beijing 2022” Protests At Olympic Torch Ceremony,” January 2022, https://studentsforafreetibet.org/human-rights-activists-face-legal-battle-in-greek-courts-following-no-beijing-2022-protests-at-olympic-torch-ceremony/ https://www.politico.eu/article/greek-police-arrest-activists-olympic-ceremony-disruption-beijing-tibet-protest/
Flo Marks and John Merlin, “CCP Undermining the Right to Protest in the Birthplace of European Democracy,” Index on Censorship, February 2023, https://www.indexoncensorship.org/2023/02/ccp-undermining-the-right-to-protest-in-the-birthplace-of-european-democracy/.
Henry Samuel, “France shuts down nine Chinese ‘secret police stations’” The Telegraph, June 2026 https://www.telegraph.co.uk/world-news/2026/06/18/france-shuts-down-nine-secret-chinese-police-stations/; Sofia Stuart Leeson, “Dutch FM says secret Chinese police stations have shut down”, EURACTIV, December 2022, https://www.euractiv.com/news/dutch-fm-says-secret-chinese-police-stations-have-shut-down/.
Alecci, Scilla. “Italian Authorities Order Expulsion of Chinese Agents Responsible for Spying on Dissidents.” International Consortium of Investigative Journalists (ICIJ), March 2026. https://www.icij.org/news/2026/03/italian-authorities-order-expulsion-of-chinese-agents-responsible-for-spying-on-dissidents/.
European Parliament. “MEPs Demand EU Action to Fight Transnational Repression.” European Parliament News, June 2026. https://www.europarl.europa.eu/news/en/press-room/20260611IPR45211/meps-demand-eu-action-to-fight-transnational-repression.
Group of Seven (G7), “G7 Leaders’ Statement on Transnational Repression,” G7/G20 Documents Database, June 2025, https://g7g20-documents.org/fileadmin/G7G20_documents/2025/G7/Canada/Leaders/1%20Leaders’%20Language/G7%20Leaders%E2%80%99%20Statement%20on%20Transnational%20Repression_17062025.pdf; Scilla Alecci, “Italian Authorities Order Expulsion of Chinese Agents Responsible for Spying on Dissidents,” International Consortium of Investigative Journalists, March 2026, https://www.icij.org/news/2026/03/italian-authorities-order-expulsion-of-chinese-agents-responsible-for-spying-on-dissidents/; European Parliament, “Addressing Transnational Repression of Human Rights Defenders,” A10-0206/2025, November 2025, https://www.europarl.europa.eu/delegations/en/addressing-transnational-repression-of-h/product-details/20251209DPU40583.
Laura Bicker and Kathryn Armstrong, “Thailand Deports Dozens of Uyghurs to China,” BBC, February 2025, https://www.bbc.com/news/articles/c14jjxz8re6o; Human Rights Foundation, “Corporate Intimidation & Censorship in China: Recommendations for Foreign Companies,” June 2020, https://hrf.org/latest/corporate-intimidation-and-censorship-in-china/.
European Parliament, “Addressing Transnational Repression of Human Rights Defenders,” A10-0206/2025, November 2025, https://www.europarl.europa.eu/delegations/en/addressing-transnational-repression-of-h/product-details/20251209DPU40583; Ana Sofia Harrison and Marlena Wisniak, “Automating Repression Beyond Borders: How AI is Powering Transnational Repression,” European Center for Not-for-Profit Law, March 2026, https://ecnl.org/sites/default/files/2026-03/ECNL%20Digital%20Transnational%20Repression%20AI_1.pdf.
Rome Statute of the International Criminal Court, art.7, adopted July 17, 1998, entered into force July 1, 2002, 2187 U.N.T.S. 90, https://www.icc-cpi.int/sites/default/files/2024-05/Rome-Statute-eng.pdf.
