Professor Sienho Yee has recently published a paper in Chinese Journal of International Law, entitled, “Unilateral Sanctions: Kind and Degree; Long-arm and Strong Arm Jurisdiction; Real Intent and ‘Could-be’ Intent.” Yee has ably elaborated that to assess the conduct of unilateral sanctions, there is a need to consider a question of “kind” so as to a question of “degree.” Further, the so-called “long-arm jurisdiction” should be better phrased as “strong-arm jurisdiction” since sometimes long-arm jurisdiction may be lawful, whereas the current version of the long-arm jurisdiction asserted by the United States is so extreme that it is no longer lawful. To this end, attention should be paid to the level of scrutiny or standard of review that a decision-maker would apply to the assessment of intent. Following from Yee’s thoughts, this note would like to elaborate further on another aspect, namely, the proportionality and necessity of unilateral sanctions.

1. Introduction
 2. Unilateral Sanctions
 3. Strong-arm Jurisdiction
 4. Constructive Engagement
 5. The Unilateral Sanctions and the WTO DisputeSettlement
 6. Conclusion

• Yen-Chiang Chang(Professor of International Law and Director of Institute of Bohai and Yellow Sea Studies, School of Law at Dalian Maritime University)