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On 7 February 2019, General Thomas Waldhauser, then-Commander of United States Africa Command, stated the following during a hearing of the U.S. Senate Armed Services Committee: “The Chinese bring the money and the Russians bring the muscle.”1 “Chinese money” is evident in the fact that since 2009, China has been Africa’s largest trading partner. Building upon this robust relationship, President Xi Jinping announced in September 2018, that USD 60 billion in assistance, loans, and investments would be forthcoming to African recipients.2 “Russian muscle” in Africa is increasingly evident through Moscow’s reliance upon private military and security companies (PMSCs)—such as the Wagner Group— to do its bidding in countries like Libya, Sudan, and Central African Republic.

This article does not dispute the Commander’s wide-ranging assertions about the United States’ two appointed great power rivals, but it does contend that U.S. policymakers should also consider Chinese PMSCs, the “Chinese muscle” often found alongside “Chinese money.” Moreover, one should contemplate the Chinese PMSC presence beyond Africa. As China develops a global footprint, for example through geoeconomic and geostrategic efforts such as the Belt and Road Initiative (BRI), its dependence upon PMSCs too will expand.

To make its case, this article has two parts. First, it presents the rationale for why China is increasingly relying upon PMSCs. The article identifies the growing vulnerabilities that have accompanied China’s advancing global presence and the merits of a Chinese PMSC solution. Second, the article suggests the need for U.S. engagement vis-à-vis the Chinese PMSC issue despite its potential implications for China’s expansionism. Indeed, the BRI, Chinese interactions with Africa, and Beijing’s endeavors elsewhere will continue, thus maintaining its reliance on PMSCs. Additionally, the Chinese PMSC industry is in the midst of flux. Its eventual orientation is a matter of concern given that the United States has been the global champion of a defensively oriented and transparent PMSC industry. The United States assuredly wishes to dissuade China from following the assertive, offensive, and deniable route taken by Russia and its reliance upon firms. As such, the article contends that U.S. policymakers should strive, with some sensitivity, to bring China and its PMSCs more into the regulatory fold developed over the past 20 years.

Chinese Global Expansion and Security Privatization

While China has engaged in development assistance, resource extraction activities, and infrastructure projects with African partners since the 1990s, the BRI is of a newer vintage and on a transcontinental scale. Announced by President Xi in 2013, China is working in more than 80 countries in Central, South, and Southeast Asia, the Middle East, and the Horn of Africa to construct energy, land and maritime transportation, and communications networks with and through them, ending at the European Union. At its planned fruition, the BRI will connect 70 percent of the earth’s population and be linked to countries generating 55 percent of the world’s gross domestic product, and locales of 75 percent of global energy reserves.3 With the level of investment reaching perhaps as high as USD 4 trillion, the BRI is nothing less than “a Marshall Plan with Chinese characteristics.”4

Taking the mature China-Africa relationship and the upstart BRI together, Chinese interests are now considerably exposed to security upheaval well beyond China’s borders. Wang Duanyong and Zhao Pei categorize these overseas challenges as “extraneous risks” and “endogenous risks.”5 Extraneous risks are those that Chinese actors confront in the often weak state, conflicted environments in which they invest, extract, and work. Criminality, extremism, terrorism, ethnic strife, and separatism frequently blight the countries in which China pursues its interests. Moreover, non-state actors may target the Chinese presence because of its perceived assistance to host government authorities. For example, in recent years, Chinese interests have been so targeted in South Sudan and Pakistan.

In contrast, endogenous risks are those of Chinese origin. Anti-Chinese sentiment may arise due to poor working conditions, the upset caused to the local economic status quo, a disregard for environmental degradations, a failure to engage fulsomely with local populations, and cultural insensitivity.6 In some instances, resentment can surface because the hiring of locals is in fact limited given a Chinese penchant for “whole chain industry export.”7 Extraneous and endogenous risks can combine when the Chinese presence becomes embroiled in a host country’s political dynamics. In Kenya, Zambia, South Sudan, the Maldives, Malaysia, and elsewhere, governing and opposition politicians in the midst of their politicking have decried the Chinese presence and the corruption that has allegedly occurred, leading to increased antipathy and heightened tensions.8

Though Beijing would like to rely upon local forces to provide security, host government authorities may be unable or unwilling to provide Chinese workers and businesses with adequate protection. The very weakness of many states in which China invests means that military and police bodies are often underpaid, overstretched, poorly trained, and riven by the same tensions affecting the state writ large. For instance, Chinese personnel working in the Democratic Republic of Congo report of routinely being subject to “legitimate harm” at the hands of soldiers and police officers.9 In Iraq, one Chinese business called upon the local police in response to looting only to see the responding officers join in the fray.10

The dangers Chinese citizens and operations confront overseas and the varying responses of local forces have caught the attention of Chinese officialdom. In 2012, the People’s Daily, the official newspaper of the Central Committee of the Communist Party of China, printed the following: “China should deeply study the diplomatic protection issue… China should also discuss how China strengthens its diplomatic influence… so that China can safeguard its national interests and protect its citizens to the maximum extent.”11 In terms of hard measures, note now the training offered by Chinese peacekeepers and other military personnel. Consider also that China is presently the second largest arms exporter to Africa. In terms of soft measures, the Chinese leadership hopes that economic improvements catalyzed by Chinese engagement will improve security outcomes overall. In 2014, President Xi promoted sustainable development as the way forward for security: “We need to focus on development, actively improve people’s lives and narrow down the wealth gap so as to cement the foundation of security.”12 Nevertheless, only certain weapons are appropriate for protecting Chinese workers and worksites, embedding the lessons from training takes time, and reforming political, economic, and cultural issues takes even longer.

Yet reliance instead upon the People’s Liberation Army (PLA) in a consistent and substantial way is also problematic. As the RAND Corporation’s Timothy Heath identifies, the overseas protection of China’s rights and interests is not fundamentally conceived as a military problem. True, Heath does recognize a Chinese capability to transport and operate military forces abroad, but this is a nascent and limited capability.13 Moreover, other obstacles confronting greater PLA engagement include the following: complications concerning China’s official non-interference policy; the symbolism of a PLA presence on land; potential concerns of escalation and a related tentativeness due to a lack of combat experience; the financial implications of funding such operations; and concerns that a robust PLA presence could unduly confound Beijing’s regional diplomatic relationships.14 One former PLA officer captures the limitations thus: “The need for security protection overseas is quite significant and the army is clearly not suitable for this job due to the potential problems it might cause for foreign relations.”15

With the security demand not readily satisfied, the regulatory and political milieus have become increasingly supportive of a Chinese PMSC presence overseas. On 28 September 2009, the Executive Meeting of the State Council adopted the “Regulation on the Administration of Security and Guarding Services” which came into force 1 January 2010. This regulation provides some guidance on the requirements for registration and operations domestically and abroad. Lest there be concerns that Chinese PMSCs might work against the state, Article 78 of China’s 2015 National Security Law draws all non-state actors to the cause of China’s national security: “State organs, mass organizations, enterprises, public institutions, and other social organizations shall cooperate with relevant departments in employing relevant security measures as required by national security efforts.”16 Finally, top level sanction came in the wake of attacks against the Chinese presence in South Sudan in 2016. President Xi embraced the sorts of activities performed by PMSCs by identifying a requirement for “improved safety risk evaluation, monitoring and pre-warning, and the handling of emergencies.”17

The result has been a burgeoning private security industry. Domestically, 2017 statistics reveal an industry 5,800 firms strong that employs approximately five million personnel.18 China’s domestic private security industry is now one of the largest in the world with a growth rate of approximately 20 percent annually.19

Internationally, the Chinese PMSC footprint, while smaller than some others, is growing in size and importance. Consider these examples. Dewei Security Group Limited protects both the China Road and Bridge Corporation’s efforts to construct the Nairobi-Mombasa railway and the China National Petroleum Corporation’s work in Sudan and South Sudan. It also provides security services to Chinese Poly-GCL Petroleum Group Holdings’ Liquefied Natural Gas undertakings in Ethiopia. Huaxin China Security performs counter-piracy work on Chinese flagged ships operating off the Horn of Africa and in Southeast Asian waters. Guanan Security & Technology guards ZhenHua Oil’s activities in Iraq. Other firms are active in Afghanistan, Cambodia, Iraq, Libya, Malaysia, Mongolia, Mozambique, Pakistan, Thailand, Turkey, and elsewhere working mostly for state-owned enterprises (SOEs). In total, approximately 30 Chinese firms offer their services overseas.20

Several factors capture the appeal of utilizing Chinese PMSCs specifically. Given the largely Chinese clientele, Chinese PMSCs can offer a common working language and respect cultural affinities.21 As one Dewei official put it, “For Chinese firms, especially with security work, they… want to speak with another Chinese person. We can also one hundred percent reflect their thinking when we work.”22 Another factor is cost. Whereas foreign PMSCs often have more experience, it comes at a cost Chinese clients are unwilling to bear. Some calculations suggest that 12 Chinese guards equate to the cost of one U.S. or British guard.23 Lastly, and related to this, Chinese personnel are preferred over foreigners given sensitivity to protecting the confidential information of SOEs. Chinese PMSC personnel with former military, police, or government experience seemingly pass an implicit higher loyalty test.24 Therefore, it is not surprising that many Chinese PMSCs working abroad have their Beijing offices near SOE headquarters and the Chinese Ministry of Foreign Affairs.25

Looking to the future, opportunities seemingly abound for Chinese PMSCs. A managing director of the Chinese Overseas Security Group assessed in 2017 that “In eight years’ time, we want to run a business that can cover 50–60 countries, which fits with the One Belt One Road coverage.”26 Given that 2016 assessments found that Chinese PMSC personnel working abroad outnumbered PLA personnel on United Nations duty—3,200 to 2,600—Chinese PMSCs are an important element of China’s international posture.27 In fact, for one industry watcher, China’s swelling global presence and the quantitative expansion of Chinese PMSCs operating internationally taken together mean that the role Chinese firms play in “the security arena is going to affect not only the security actors but also the security stage as a whole.”28

U.S. Engagement: Reasons and Response

On the one hand, the Chinese presence in Africa and a successful implementation of the BRI inherently challenge U.S. interests and standing in many parts of the world. Though the United States has implemented countering initiatives such as the Build Act, they do not match the scale of Chinese financing and infrastructure efforts.29 These activities will likely open up new markets that will help China and others to wean themselves from their reliance on the U.S. market and the U.S. dollar.30 Coupled with its material gains, China’s endeavors will ideationally advance authoritarian capitalism, rather than free market capitalism championed by the United States, as a way of doing business globally. Absolutely and relatively to the United States, China will garner more sway abroad either through its welcomed largesse or through foreign governments now being economically indebted to Beijing.31 In short, these developments easily fall into the 2017 National Security Strategy’s worries that China wants “to shape a world antithetical to U.S. values and interests.”32

On the other hand, U.S. policymakers might also benefit from a degree of perspective—the BRI’s fulsome success is no sure thing and Beijing has already encountered challenges in Africa. True, speaking about the BRI specifically in May 2017, President Xi asserted that the initiative “should focus on the fundamental issue of development, release the growth potential of various countries and achieve economic integration and interconnected development and deliver benefits to all.”33 The Chinese narrative for the BRI and elsewhere is that China works to develop “win-win” relationships. Nevertheless, according to one China observer, “win-win cooperation is perceived as ‘China is going to win twice.’”34 As indicated earlier, such a dynamic increases political tensions among the governments, political parties, and populations of target countries.

Regarding China’s specific reliance upon PMSCs in this milieu, this author’s contention is that the United States should not look away. This is counterintuitive because, at first glance, the above might suggest that the United States should not concern itself. From one angle, China’s usage of PMSCs may help to make secure various Chinese economic and political initiatives that will negatively affect the United States in a zero-sum fashion. Why should the United States help this relationship to flourish? From another angle, China faces considerable problems abroad and Beijing’s usage of PMSCs speaks, in part, to this generated resistance. Why should U.S. policymakers expend limited diplomatic resources to ameliorate China’s sometimes fraught relationships?

To contextualize the reasons for a U.S. response, one should recognize that the United States is the global champion of a defensively oriented and transparent PMSC industry. This was made plain during the military activities in Afghanistan, Iraq, and elsewhere in this century that set the United States as the world’s largest consumer of PMSC services. Certainly, U.S. officials have not denied their reliance upon PMSCs. If anything, government officials promote contractors writ large as part of the “Total Force Concept.” As a regulator it is important to note the U.S. Department of Defense’s 2012 decision to contract ASIS International and the American National Standards Institute to create the PSC.1 Standard. This standard buttresses the industry’s defensive credentials that U.S. hiring decisions in turn reinforce. Moreover, other states now use the standard in their PMSC procurement efforts.35

One can also applaud the United States as a setter of international norms for a variety of actors. The United States is an initial signatory to the 2008 Montreux Document on PMSCs.36 In the Document, “Military and security services include, in particular, armed guarding and protection of persons and objects, such as convoys, buildings and other places; maintenance and operation of weapons systems; prisoner detention; and advice to or training of local forces and security personnel” (italics added).37 The document also recommends various procedures that publicly set relationships between states and firms. This document has 56 state signatories as of June 2019.

Building on this, the United States, along with only six other countries, is a member of the International Code of Conduct Association (ICoCA). This association concerns, in many ways, Montreux Document-related matters. This is through its advancement of the 2010 International Code of Conduct for Private Security Service Providers (ICoC), the industry’s response to the Montreux Document. Like the Montreux Document, the ICoC has a defensive focus: firms are not to “use firearms against persons except in self-defence or defence of others against the imminent threat of death or serious injury, or to prevent the perpetration of a particularly serious crime involving grave threat to life.”38

In addition, predating the Montreux Document, the United States has been attentive to PMSC usage by non-state actors such as resource extraction companies. For instance, the 2000 Voluntary Principles on Security and Human Rights is a multi-stakeholder initiative involving states and non-governmental organizations, oil, gas, and mining companies that espouses a defensive focus: “Consistent with their function, private security should provide only preventative and defensive services and should not engage in activities exclusively the responsibility of state military or law enforcement authorities.”39 In short, PMSCs are not to use offensive violence on behalf of their commercial clients.

It follows that there are three reasons why the United States should engage on the Chinese PMSC issue. First, Chinese economic and political dynamics that are not going to disappear drive China’s reliance on PMSCs. Chinese economic growth, a key element for domestic calm, has slowed, catalyzing Beijing to look to Africa and Asia particularly in order to export its excess capacity and to find new markets for consumer goods.40 The fact that President Xi, unburdened by term limits since 2018, has linked himself closely to the BRI further extends the horizon. Indeed, Beijing has invested so much in the BRI that, for one Chinese analyst, it is “the essence of the realisation of the Chinese dream and the rejuvenation of our nation… It is the framework for foreign policy in the decades to come.”41 Overall, China’s international outreach towards multiple continents, and the associated PMSC usage, will continue.

The second reason for U.S. engagement is that in the midst of China’s continued reliance, there is great potential for change in the orientation of Chinese PMSCs. To explain, most Chinese PMSCs presently lack substantial capabilities to inflict lethal violence. Though the aforementioned 2010 regulation loosened restrictions on China’s private security industry, rules remain in place regarding firearm possession. With the exception of firms conducting counter-piracy work at sea, the government does not permit Chinese PMSCs to use firearms abroad. Instead, Chinese PMSCs have focused on security within compounds and have generally relied upon non-lethal weaponry, martial arts, negotiation skills, local intelligence collection, and crisis management and evacuation procedures. In challenging environments, Chinese PMSCs are to rely either upon locally contracted security firms who can carry arms or upon Chinese embassy and consular officials for assistance.

This approach has its limits and there is evidence of some workarounds given the dangers involved. Non-lethal measures may not provide the necessary deterrence. Local private security may not have the requisite capabilities, skillsets, or professionalism. Chinese government officials are often at great distance from the threatened worksite or living quarters and they have to count on their relationships with a sometimes shaky host security sector described above. As such, media reports indicate a persistent dilemma that confronts PMSCs: stay unarmed or delve into the local black market for weaponry.42 Others indicate that firms have borrowed firearms from the local security firms.43 Underscoring the need to arm their personnel, some firms have made arrangements abroad for firearms training.44

Additional change, going beyond a more robust defensive posture through firearms usage, might arrive through Chinese concepts and an experiential record concerning non-state actors that could frame an offensive use of PMSCs. Conceptually, since 2003, the Communist Party and China’s Central Military Commission have embraced the so-called “Three Warfares” concept. While one can find an in-depth consideration of this approach elsewhere, it is important to stress for this article that it places less emphasis on violence delivered by state armed forces.45 Instead, “Three Warfares” pays greater attention to a wider variety of tools, including state and non-state actors, which are neither as costly nor imbued with the same degree of symbolism. As Laura Jackson suggests, this stance is “a significant shift away from current understandings of war as defined primarily by the kinetic and tangible, and towards one focused more on thought processes, mental impressions, and the will to act.”46 Yet the concept’s tools can be coercive in their own way and are the means to achieve strategic objectives. To explain further, these tools, used alone or in combination, are not as likely to spark a considerable response from adversaries prohibiting China’s task achievement. In fact, their usage may be ambiguous, thus further hindering the reactions of others. Moreover, utilization of the “Three Warfares” is constant, thus blurring the boundaries between war and peace. As asserted by Elsa Kania: “the application of the three warfares is intended to control the prevailing discourse and influence perceptions in a way that advances China’s interests, while compromising the capability of opponents to respond.”47

The realization of this concept is evident through Chinese practices at the country’s peripheries. As Lora Saalman contends, China relies upon “‘little green men’ (nomads and paramilitaries at land borders) and ‘little blue men’ (fishermen and coastguard vessels at maritime borders)” to expand its influence.48 Reliance on these actors keeps the Chinese military in the background while the status quo is nevertheless upended in China’s favor by means of incremental moves, coercion, and ambiguity. James Kraska asserts that such an approach augments “operational, legal and political challenges for any opponent ... [it] complicates the battlespace, degrades any opponent’s decision-making process and exposes adversaries to political dilemmas that will make them more cautious to act against China.”49

Though China uses this approach in areas of proximity to the mainland, one can argue that it might be employed further away. Indeed, China’s approach towards the South China Sea is arguably a testing ground for future activism.50 In this vein, the successful spread of the BRI might recast what is deemed as China’s periphery, at least in a strategic sense.

In sum, one should not shy away from considering the future trajectory of Chinese PMSCs given these ideas and evolving practices. Without a doubt, they would stand contrary to the U.S. experience and how the U.S. approach has framed the defensive and predictable character of the international PMSC industry.

The third reason for U.S. engagement is to dissuade China from mimicking the route taken by Russia in its usage of PMSCs. Not only has Russia relied upon companies in a generally offensive manner, as a non-signatory to the Voluntary Principles on Security and Human Rights, it has advocated a particularly aggressive posture vis-à-vis resource producing areas. For instance, a Syrian-Russian agreement permits Russian extractive companies to accrue 25 percent of the proceeds produced from regions external to Damascus’ control. To capture these regions, PMSC reliance is required. On the one hand, Moscow has put this development in the context of countering international terrorism. President Putin commented that “members of these firms are risking their lives in the fight against terrorism by retaking oil wells and infrastructure that had been controlled by the Islamic State.”51 On the other hand, one should recall the February 2018 clash in Syria between U.S. forces and the Russian firm Wagner. This is because near the battle site was the Coneco oil processing facility under non-ISIS and non-regime control.52 Due to the aggressive bent of some Chinese non-state actors, the resource-centric elements of China’s relationship with Africa and the BRI, and the fact that China also is not a signatory to the Voluntary Principles on Security and Human Rights, one could envision a more provocative and assertive China following a similar path.

Furthermore, there are potential similarities between Russia and China regarding transparency. For Russia, a non-signatory to the Montreux Document, despite high-level recognition that firms like Wagner are working abroad, Moscow denies official control and responsibility. Again, to quote President Putin, companies “are indeed present there [Syria]… However, they are related to neither the Russian government, nor the Armed Forces; therefore, we have no comment.”53 Nevertheless, according to analyst Mark Galeotti, connections with the state are plain: firms are “‘hybrid businesses,’ technically private, but essentially acting as the arms of the Russian state.”54 For China, PMSC usage is a prospective tool to avoid negative outcomes that might be associated with a PLA mission abroad and an official disruption of the aforementioned non-interference policy. Because former members of China’s state security sector populate firms, they are possibly “a parallel security strategy” upon which the Chinese state can rely.55 Also, similar to Russian firms being both celebrated and denied, analysts from Merics and the International Institute for Strategic Studies contend that firms permit China “plausible deniability in worst-case scenarios whilst reaping the PR benefits of successful missions in the best-case scenarios.”56 For the United States then, Russian deniability vis-à-vis PMSCs has already proven problematic in the context of gray zone conflict.57 Diverting China from considering a similar path would no doubt be optimal from the U.S. perspective.

The resulting U.S. approach orchestrating this diversion will require some delicacy. In part, this is because it concerns relations between peer competitors. It is unlikely, therefore, that Beijing would embrace, upon Washington’s suggestion, the PSC.1 Standard in the hiring of Chinese PMSCs. Simply put, China following an overt U.S. policy is doubtful. In part, this is also because some of the international measures noted above rest predominantly upon the promotion of human rights, a longstanding sensitive matter both within China and concerning its activities overseas. Indeed, China frequently pushes back against human rights advocates.58 Hence, pressing China to embrace overtly the Voluntary Principles on Security and Human Rights would probably be counterproductive. In addition to security privatization, the principles concern other matters that China would surely find troubling: the actions of public security forces (upon which China still relies) and how the policies of extraction companies might aggravate political, economic, civil, and social factors that heighten risk.

In contrast, measures related to the Montreux Document may hold greater promise. Though the Document concerns human rights, humanitarian law obligations anchor it in a way that might be less problematic to Beijing. Like the United States, China is one of the initial signatories to the Montreux Document. But unlike the United States, China has not openly acted upon Montreux Document suggestions regarding good practices. China has yet to fully clear up policies related to exercising responsibility emphasized in the Document. Some China watchers note confusion as to which governmental ministries are responsible for Chinese PMSCs and SOEs. Also, some contend that there is a dearth of encompassing regulation (the sort which might be cleared up by a closer embrace of the document). 59 In this vein, others recommend that amidst the considerable uncertainty, Chinese PMSCs voluntarily follow the Document’s good practices.60

A potential avenue for the United States would be to promote Chinese membership in the aforementioned ICoCA with its links to the Montreux Document. Already the ICoCA has five Chinese firms/organizations as members and two other Chinese individuals serve as observers.61 From China’s perspective, ICoCA membership would permit Beijing to participate in an international venture with growing implications both domestic and global. From the U.S. perspective, Chinese involvement would hopefully tie Chinese PMSC usage closer to the defensive frame advanced in multiple ways by Washington. For instance, the association stresses that through membership, “States… commit to provide information related to their implementation of the Montreux Document and the Code, including the development of their domestic regulatory framework for… [company] activities, and to promote compliance with the ICoC in their contracting practices and policies.”62 Also, Chinese ICoCA membership would allow Beijing to remain cognizant of developments regarding the Voluntary Principles on Security and Human Rights because the ICoCA holds observer status in the associated Voluntary Principles Initiative.

Conclusion

While it is a cliché to suggest the return of great power competition, it is important to acknowledge a new actor not present during the last round: the PMSC. General Waldhauser made such a recognition in regards to Russia and this article likewise examines the increasing flexing of “Chinese muscle” through Beijing’s reliance upon PMSCs. For the United States, it is important to appreciate that China’s growing engagement through economic activities on multiple continents and through multiple policy vehicles will increasingly have a “private” face with respect to security. It is also important to understand that how China will flex its muscle in the future is uncertain.

From the U.S. perspective, it would be beneficial for China to operate in a way that is defensive, transparent, and not assertive in the context of gray zone conflict. This speaks both to how Washington would like the international management of violence writ large to operate and to steady its relations with its peer competitors. Presently, the U.S. approach, like that of many other states, is to employ PMSCs to support state militaries and/or to keep conflicts on the backburner. Firms have neither the capabilities nor the orientation to upset the status quo through the application of violence. However, already Russia employs firms to “keep the kettle boiling,” an approach that has confounded U.S. policymakers and unsettled global expectations.63 Given the Russian model and the different ways in which China’s PMSC usage might evolve, it behooves Washington to engage Beijing. This article offers a recommendation on the possible substance of that engagement. PRISM

Notes

1 The quote is initially attributed to a Congolese politician. Geoffrey York, “Pentagon warns of rising Chinese and Russian Influence in Africa,” Globe and Mail, February 11, 2019, available at <https://www.theglobeandmail.com/world/article-pentagon-warns-of-rising-chinese-and-russian-influence-in-africa/>.

2 “China raises fears of ‘new colonialism’ with $60 billion investment across Africa,” The Telegraph, September 3, 2018, available at <https://www.telegraph.co.uk/news/2018/09/03/china-invest-60-billion-across-continent-raising-fears-new-colonialism/>.

3 Sebastian Booth and Cindy J. Smith, “The Uneven Regulation of Private Security in ASEAN Member States,” in Securing the Belt and Road Initiative Risk Assessment, Private Security and Special Insurances Along the New Wave of Chinese Outbound Investments, Alessandro Arduino and Xue Gong, Eds. (Singapore: Palgrave Macmillan, 2018), 19.

4 Zack Cooper and Andrew Shearer, “Thinking clearly about China’s layered Indo-Pacific strategy,” Bulletin of the Atomic Scientists, Vol. 73, No. 5, (2017), 309; Alessandro Arduino and Xue Gong, “Introduction,” in Securing the Belt and Road Initiative Risk Assessment, Private Security and Special Insurances Along the New Wave of Chinese Outbound Investments, Alessandro Arduino and Xue Gong, Eds. (Singapore: Palgrave Macmillan, 2018), 3.

5 Wang Duanyong and Zhao Pei, “Security Risks facing Chinese Actors in Sub-Saharan Africa: The Case of the Democratic Republic of Congo,” in China and Africa: Building Peace and Security Cooperation on the Continent, Chris Alden, Abiodun Alao, Abiodun, Zhang Chun, and Laura Barber, Eds. (Cham: Palgrave Macmillan, 2018), 260.

6 Allessandro Arduino, “China’s Belt and Road Initiative Security Needs: The Evolution of Chinese Private Security Companies,” RSIS Working Paper, No. 306, (August 29, 2017), 4, 9–10, available at <https://www.rsis.edu.sg/rsis-publication/rsis/wp306-chinas-belt-and-road-initiative-the-evolution-of-chinese-private-security-companies/#.XYUHTy3MygQ>.

7 Astrid H.M. Nordin and Mikael Weissmann, “Will Trump make China great again? The belt and road initiative and international order,” International Affairs, Vol. 94, No. 2, (2018), 247.

8 Wang Duanyong and Zhao Pei, op. cit., 2018, 257; Andrew Chatzky and James McBride, “China’s Massive Belt and Road Initiative,” Council on Foreign Relations, May 21, 2019, available at <https://www.cfr.org/backgrounder/chinas-massive-belt-and-road-initiative>; Lina Benabdallah, “China’s Peace and Security Strategies in Africa: Building Capacity is Building Peace?” African Studies Quarterly, Vol. 16, No. 3–4, (2016), 27; Tanner Greer, “One Belt, One Road, One Big Mistake Foreign Policy,” Foreign Policy, December 6, 2018, available at <https://foreignpolicy.com/2018/12/06/bri-china-belt-road-initiative-blunder/>; Helena Legarda and Meia Nouwens, “Guardians of the Belt and Road: The internationalization of China’s private security companies,” Mercator Institute for China Studies, August 16, 2018, 7, available at <https://www.merics.org/en/china-monitor/guardians-of-belt-and-road>.

9 Wang Duanyong and Zhao Pei, op. cit., 2018, 255.

10 Timothy R. Heath, “China’s Pursuit of Overseas Security,” RAND Corporation, 2018, 34, available at <https://www.rand.org/content/dam/rand/pubs/research_reports/RR2200/RR2271/RAND_RR2271.pdf>.

11 Geoffrey York, “Chinese front-line overseas workers coming under increasing attack,” Globe and Mail, February 8, 2012, available at <http://www.theglobeandmail.com/news/world/chinese-front-line-overseas-workers-coming-under-increasing-attack/article2330273/>.

12 “Asia Needs Sustainable, Durable Security: Chinese president,” China Today, May 22, 2014, available at <http://www.chinatoday.com.cn/english/news/2014-05/22/content_620336.htm>.

13 Timothy R. Heath, op. cit., 2018, 4, 12.

14 Ibid., 18; Helena Legarda and Meia Nouwens, op. cit., August 16, 2018, 7–8; Andrew Erickson and Gabe Collins, “Enter China’s Security Firms,” The Diplomat, February 21, 2012, available at <http://thediplomat.com/2012/02/enter-chinas-security-firms/?allpages=yes>.

15 Charles Clover, “Chinese private security companies go global,” Financial Times, February 26, 2017, available at <https://www.ft.com/content/2a1ce1c8-fa7c-11e6-9516-2d969e0d3b65>.

16 Timothy R. Heath, op. cit., 2018, 21.

17 Charles Clover, op. cit., February 26, 2017; Alessandro Arduino, China’s Private Army: Protecting the New Silk Road (Singapore: Palgrave Macmillan, 2018a), 30.

18 Gordon Watts, “China’s ‘Private Army’ prowls the ‘New Silk Road’,” Asia Times, August 20, 2018, available at <http://www.atimes.com/article/chinas-private-army-prowls-the-new-silk-road/>; Brenda Goh, Michael Martina, and Christian Shepherd, “Local, Global Security Firms in Race Along China’s ‘Silk Road’,” US News & World Report, April 23, 2017, available at <https://money.usnews.com/investing/news/articles/2017-04-23/local-global-security-firms-in-race-along-chinas-silk-road>.

19 Mathieu Duchâtel, Oliver Bräuner, and Zhou Hang, “Protecting China’s Overseas Interests: The Slow Shift away from Non-interference,” SIPRI Policy Paper no. 41, June 2014, 54, available at <https://www.sipri.org/publications/2014/sipri-policy-papers/protecting-chinas-overseas-interests-slow-shift-away-non-interference>; Sean McFate, The Modern Mercenary: Private Armies and What They Mean for World Order (New York: Oxford University Press, 2014), 153–54.

20 Alessandro Arduino, op. cit., 2018a, 13.

21 Charles Clover, op. cit., February 26, 2017.

22 Brenda Goh, Michael Martina, and Christian Shepherd, op. cit., April 23, 2017.

23 Charles Clover, op. cit., February 26, 2017.

24 Alessandro Arduino, op. cit., 2018a, 13.

25 Alessandro Arduino, “Security Privatisation with Chinese Characteristics: The Role of Chinese Private Security Corporations in Protecting Chinese Outbound Investments and Citizens,” S. Rajaratnam School of International Studies, Nanyang Technological University, June 2015, 11, available at <https://www.rsis.edu.sg/wp-content/uploads/2015/07/PR150630_Security-Privatisation.pdf>.

26 Brenda Goh, Michael Martina, and Christian Shepherd, op. cit., April 23, 2017.

27 Charles Clover, op. cit., February 26, 2017.

28 Alessandro Arduino, op. cit., June 2015, 14.

29 Andrew Chatzky and James McBride, op. cit., May 21, 2019; William C. Pacatte, III, “Be Afraid Be Very Afraid Why the United States Needs a Counterstrategy to China’s Belt and Road Initiative,” Defense360, October 19, 2018, available at <https://www.csis.org/analysis/be-afraid-be-very-afraid—why-united-states-needs-counterstrategy-chinas-belt-and-road>; Bob Jones, “Challenge Accepted: Why America Needs to Confront Its Adversaries in the Gray Zone,” The National Interest, April 29, 2019, available at <https://nationalinterest.org/feature/challenge-accepted-why-america-needs-confront-its-adversaries-gray-zone-55027>; Travis Reese, “Beating Them at Their Own Game: The Economic Dimension of Competing With China,” War on the Rocks, August 9, 2018, available at <https://warontherocks.com/2018/08/beating-them-at-their-own-game-the-economic-dimension-of-competing-with-china/>.

30 Alessandro Arduino, “China’s Belt and Road Security: The Increasing Role of Insurance and Private Security Companies,” in Securing the Belt and Road Initiative Risk Assessment, Private Security and Special Insurances Along the New Wave of Chinese Outbound Investments, Alessandro Arduino and Xue Gong, Eds. (Singapore: Palgrave, 2018b), 54; Gal Luft, “Silk Road 2.0: US Strategy toward China’s Belt and Road Initiative,” Atlantic Council Strategy Paper No. 11, October 2017.

31 Travis Reese, op. cit., August 9, 2018; Andrew Chatzky and James McBride, op. cit., May 21, 2019; Mikael Wigell, “Hybrid interference as a wedge strategy: a theory of external interference in liberal democracy,” International Affairs, Vol. 95, No. 2, (2019), 265.

32 National Security Strategy of the United States of America, December 2017, 25, available at <https://www.whitehouse.gov/wp-content/uploads/2017/12/NSS-Final-12-18-2017-0905.pdf>.

33 William C. Pacatte, III, op. cit., October 19, 2018.

34 Alessandro Arduino, op. cit., 2018b, 43.

35 United States Department of Defense, “Private Security Companies – Standards,” Office of the Assistant Secretary of Defense for Sustainment, available at <https://www.acq.osd.mil/log/ps/psc_Standards.html>; Deborah D. Avant, “Pragmatic Networks and Transnational Governance of Private Military and Security Services,” International Studies Quarterly, Vol. 60, No. 2, (2016), 339.

36 The document’s full name: The Montreux Document on Pertinent International Legal Obligations and Good Practices for States Related to Operations of Private Military and Security Companies During Armed Conflict.

37 “The Montreux Document On pertinent international legal obligations and good practices for States related to operations of private military and security companies during armed conflict,” 2008, 9, available at <https://www.icrc.org/eng/assets/files/other/icrc_002_0996.pdf>.

38 International Code of Conduct Association, “International Code of Conduct for Private Security Service Providers,” available at <http://www.state.gov/documents/organization/150711.pdf>.

39 US Department of State, “Voluntary Principles on Security and Human Rights,” December 20, 2000, available at <http://www.state.gov/www/global/human_rights/001220_fsdrl_principles.html>.

40 Andrew Chatzky and James McBride, op. cit., May 21, 2019.

41 Astrid H.M. Nordin and Mikael Weissmann, op. cit., 2018, 243.

42 Zi Yang, “China’s Private Security Companies: Domestic and International Roles,” China Brief, October 4, 2016, available at https://jamestown.org/program/chinas-private-security-companies-domestic-international-roles/.

43 Charles Clover, op. cit., February 26, 2017.

44 Karthie Lee, “Chinese Private Security Firms Go Overseas: ‘Crossing the River by Feeling the Stones’,” Africa Monitor, September 8, 2014, available at <http://www.fsgroup.com/chinese-private-security-firms-go-overseas-crossing-the-river-by-feeling-the-stones/>; “Crouching guard, hidden danger for China security firms,” South China Morning Post, January 17, 2013, available at <http://www.scmp.com/news/china/article/1130179/crouching-guard-hidden-danger-china-security-firms>.

45 The three elements are public opinion, psychological, and legal. For an in-depth consideration of “Three Warfares” please see the following: Sangkujk Lee, “China’s ‘Three Warfares’: Origins, Applications, and Organizations,” Journal of Strategic Studies, Vol. 37, No. 2, (2014), pp. 198–221.

46 Laura Jackson, “Revisions of Reality: The Three Warfares—China’s New Way of War,” in Information at War: From China’s Three Warfares to NATO’s Narratives, Transitions Forum, Legatum Institute, September 2015, 12.

47 Elsa B. Kania, “The PLA’s Latest Strategic Thinking on the Three Warfares,” China Brief, August 22, 2016, available at https://jamestown.org/program/the-plas-latest-strategic-thinking-on-the-three-warfares/.

48 Lora Saalman, “Little Grey Men: China and the Ukraine Crisis,” Survival, Vol. 58, No. 6, (2016–2017), 143.

49 James Kraska, “China’s Maritime Militia Upends Rules on Naval Warfare,” The Diplomat, August 10, 2015, available at <https://thediplomat.com/2015/08/chinas-maritime-militia-upends-rules-on-naval-warfare/>.

50 Laura Jackson, op. cit., September 2015, 12.

51 Sergey Sukhankin, “New Russian PMC Spotted in Syria: Potential Military Links and Implications,” Eurasia Daily Monitor, August 7, 2019, available at <https://jamestown.org/program/new-russian-pmc-spotted-in-syria-potential-military-links-and-implications/>.

52 Joshua Yaffa, “Putin’s Shadow Army Suffers a Setback in Syria,” The New Yorker, February 16, 2018, available at <https://www.newyorker.com/news/news-desk/putins-shadow-army-suffers-a-setback-in-syria>.

53 Sergey Sukhankin, op. cit., August 7, 2019.

54 Mark Galeotti, “Moscow’s Mercenaries in Syria,” War on the Rocks, April 5, 2016, available at <https://warontherocks.com/2016/04/moscows-mercenaries-in-syria/>.

55 Charles Clover, op. cit., February 26, 2017.

56 Helena Legarda and Meia Nouwens, op. cit., August 16, 2018, 14.

57 Christopher R. Spearin, “Russia’s Military and Security Privatization,” Parameters, Vol. 48, No. 2, (2018), 40.

58 Sophie Richardson, “Is China winning its fight against rights at the UN?” Human Rights Watch, December 12, 2018, available at <https://www.hrw.org/news/2018/12/12/china-winning-its-fight-against-rights-un>.

59 Helena Legarda and Meia Nouwens, op. cit., August 16, 2018, 10; Alessandro Arduino, op. cit., 2018a, 29, 49.

60 Karthie Lee, op. cit., 2014.

61 International Code of Conduct Association, “Membership,” available at <https://www.icoca.ch/en/membership>; International Code of Conduct Association, “Observers,” available at <https://www.icoca.ch/en/membership/observers>.

62 International Code of Conduct Association, “The Articles of Association,” available at <https://icoca.ch/en/articles_of_association#article-3-membership>.

63 Maxim Worcester, “Putin’s Proxy Warfare Strategy.” ISPSW Strategy Series: Focus on Defense and International Security, No. 282, August 2014, 3, available at <https://www.files.ethz.ch/isn/182503/282_Worcester.pdf>