Foreign PolicyResearchChina’s Digital Silk Road in Morocco: The Implications of Digital Sector Dominance

In the short term, DSR may serve Morocco to strengthen its digital infrastructure, but the long-term repercussions may create serious risks of cyber espionage, mass data collection, and political leverage that should not be ignored.

 

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Introduction

Morocco is the first North African nation to commit to China’s Belt and Road Initiative (BRI) implementation plan.[1] As China continues to spread its reach further west, Morocco will become an increasingly important strategic gateway to the Mediterranean. However, Chinese investment in Morocco predates this BRI agreement. Chinese technology and digital infrastructure is utilized throughout the country, across multiple industries. While much has been written about the efficacy of physical BRI projects in North Africa, Chinese dominance in Morocco’s digital sector has been largely overlooked, despite its considerable economic, geopolitical, and security implications.

The Belt and Road Initiative is Chinese President Xi Jinping’s signature project, and the world’s largest infrastructure program.[2] Chinese investment in Africa– an estimated $153 billion between 2000 and 2019–has provided key economic stimulus,[3] and has filled a void in capital investment, hard infrastructure, and technology development that western partners have failed to fill.[4] The Chinese government introduced the Digital Silk Road (DSR) in 2015 as a component of its Belt and Road Initiative. It is essentially a rebranding of the technology dimension of the BRI and encompasses “the development of the digital service sector, such as cross-border e-commerce, smart cities, telemedicine, and internet finance.”[5] It intends to accelerate “technological progress including computing, big data, Internet of Things, artificial intelligence (AI), block chain, and quantum computing.”[6] Using the DSR, China aims to pave the way for Chinese companies to become the standard for communication technologies around the world; increase China’s influence over technology, cybersecurity, and surveillance norms.[7]

However, a partnership with China comes with additional conditions, which often escape the economic projections marketed to potential clients.[8] The evidence outlined in this paper will examine the credibility of these alleged risks, specifically in regard to the DSR, in order to weigh them against the incontrovertible economic benefits. Based on this research and analysis, this work concludes that the western demonization of Chinese BRI investment is largely unfounded, as there is little evidence to show that China’s projects are “debt traps,” and the risks of investment are equivalent in the private sector;[9] however, the long-term repercussions of reliance on Chinese technology and digital infrastructure create serious risks of cyber espionage, mass data collection, and political leverage that should not be ignored.

 

Pragmatic Partnership

 While most Moroccan economic interests still currently lie with Western states,[10] King Mohammed VI has sought to diversify Morocco’s international economic partnerships, and China appears to be the ideal partner.[11] The King has emphasized the economic inequalities inherent in the trade relationship between the EU and Morocco.[12]Given this desire for economic diversification and a better bargaining position with the EU, China’s BRI has come at an ideal time for Morocco.

Between 2011 and 2015, Chinese investment in Morocco increased by 195 percent, with a 93 percent increase between 2014 and 2015. Although, this can largely be attributed to the Noor solar plant investment in 2014.[13] In May 2016, President Xi and King Mohammed announced the establishment of a strategic partnership and signed numerous agreements in a variety of economic sectors.[14] Thus, China had already begun to significantly increase its investments in Morocco before Morocco officially signed onto the BRI.[15]

First, there are multiple investments which focus on industry, free trade, and finance centers. This includes Chinese investment in the Casablanca Finance City, Huawei’s regional logistics center at the Tangier Med Port Complex, and China Communications Construction Company’s partnership to build the Mohammed VI Tangier Tech City.[16]

Second, according to AidData, a research leader on BRI data collection, China has previously committed funds to seven additional projects that fall within the scope of BRI in Morocco so far, five of which are associated with education.[17] Three of these educational project investments are related to establishing Confucian Institutes at various universities throughout Morocco.[18] Cultural connectivity has always been a focal point for President Jinping’s BRI, and establishing Chinese cultural education facilities is aimed to normalize Chinese presence abroad. The other two investments are approximately $300 million preferential buyer’s credit for the Jerada Coal-Fired Power Plant Construction Project, and a $184 million buyer’s credit loan for an expressway construction project.[19]

However, “the world’s most valuable resource is no longer oil, but data.”[20] For Morocco, which has developed and prospered without its own supply of oil, the digital age represents an enormous opportunity for the country to focus less on traditional capital projects and invest in the immaterial digital economy. China has taken notice of Morocco’s potential in this regard and will likely have a large role in facilitating its quantum leap both economically and technologically.

 

Digital Silk Road in Morocco

 The Fourth Industrial Revolution has begun, and is characterized by big data, artificial intelligence, cloud computing.[21] It will continue to cultivate a fundamental shift in socio-economic development and global economic markets. In the words of  King Mohammed VI’ speech: “Africa is on its way to becoming a global digital laboratory. Spurred on by young people’s ingenuity, creativity, and audacity, digital technology is changing the face of our Continent.”[22]

The “Morocco Digital 2025” plan is Morocco’s comprehensive domestic strategy to achieve three main goals: first, to establish a successful digital administration; second, to create a competitive economy based on the performance gains created by a digitally innovative ecosystem; and third, to foster an inclusive society thanks to widespread digital connectivity.[23] The Chinese tech giant, Huawei, is China’s main technology-related company for developing DSR projects in Morocco, and it will likely play a major part in cultivating this digital revolution.[24] The company has already established a logistics center at Tangier Med Port, provides communication technology for the national railway system (ONCF), and is deeply involved in telecommunication systems across the country.[25]

The Moroccan digital economy faces significant challenges. Broadband infrastructure penetration[26] in Morocco–17.5 percent of households for fixed broadband and 41 percent of the population for mobile broadband in 2015–is one of the lowest in the Middle East/North Africa region (MENA); whereas the regional average in 2015 was 41 and 85 percent, respectively.[27] Further, according to the World Bank, the MENA region’s labor market has been unable to adapt quickly enough, and a skills gap has hindered Morocco’s digital growth.[28] Morocco is also known for exporting its most talented students. Many Moroccans with advanced technical skills who would thrive in the communication technology sector, choose to live and work abroad for higher-paying opportunities.[29]

Chinese technology companies offer competitive pricing, low production costs, cost-effective equipment, and access to state-subsidized funding and support. Huawei has worked closely with the Moroccan government to implement a comprehensive system to support Morocco from the ground up. Using the “Industry-Academia-Government Cooperation Model,” Huawei signed a strategic partnership with Morocco’s Ministry of National Education, Vocational Training, Higher Education and Scientific Research institutions, in addition to partnership agreements with 21 universities and education institutions.[30] Huawei has established regional logistic centers and plans to roll out 5G capabilities in Morocco in 2023.[31] With its low latency, high multi-Gbps (Gigabytes per second) peak data rate speed, high reliability and huge network capacity, 5G is expected to create a major shift in industry potential for Morocco.[32]

However, the establishment of robust technical education could be China’s greatest gift to Morocco and will be extremely valuable during this technological transition. By bundling its cheap, high-quality products and systems with training, maintenance, and development programs in Morocco, Huawei has to ensure that these systems can be run effectively by Moroccans.[33] The 5G network set to be implemented will then act as a catalyst, as it will increase demand and opportunities for skilled individuals in the tech industries and “will have a major effect across vertical industries in the medium to long term.”[34] Thus, Huawei has provided a critical steppingstone for Morocco as it endeavors to meet the goals outlined in the Morocco Digital 2025 plan.

The Mohammed VI Tangier Tech City is another major Chinese-partnership project that was originally announced in 2016, but has faced crippling delays due to ownership disagreements.[35] Similar Chinese projects aim to build entirely new mixed-used urban areas; which aim to create industrial development zones, business districts, and residential, retail, and medical areas from the ground up.[36] These “built from scratch” cities are inherently integrated with technology, and generally come equipped with surveillance systems to reduce crime and improve efficiency.[37]

Although, these aspirations have not yet come to fruition. The proposal for the Tangier Tech City was for a $10 billion, 7.7 square-mile industrial and technological city said to house 300,000 people and create up to 100,00 jobs.[38]Ilyas El Omari, the head of the Tangier-Tetouan-Alhoceima region stated that, “there were disagreements on the ownership of the city among other issues. Our partners are Chinese, but this does not mean that the city belongs to Chinese.”[39] In April of 2021, China’s Road and Bridge Corp signed a memorandum of understanding with Moroccan based BMCE Bank to revive the development plans, but ground has yet to be broken.[40] Moroccan officials’ unwillingness to compromise ownership interests during negotiations demonstrates an important point: Morocco is holding firm to its developmental autonomy and will not sacrifice it for a lucrative business opportunity.

This project is set to complement the expansion of the Tangier Med Port complex, which now has the largest container handling capacity in the Mediterranean Sea and is in a pivotal strategic position on the Straight of Gibraltar.[41]In sum, each of these BRI/DSR projects have the potential to invigorate growth, promote Morocco’s digital economy, and attract additional foreign investment. On the surface, there seems to be little reason for concern in regard to these progressive and foresightful investments.

 

Digital Silk Road Risks

The continued facilitation of infrastructure in Morocco further advances China’s broader goals related to BRI and DSR, regardless of whether China is the financer, builder, owner, or operator. As Chinese companies export technology bundles such as satellites, submarine cables, data centers, 5G-based networks, and internet services, these bundles come intact with artificial intelligence and data analytic capabilities.[42] DSR will provide Chinese companies with massive amounts of data by increasing their global collection capabilities. For example, Chinese companies sell “smart ports,” which are intended to create efficiencies in the loading and unloading processes of maritime ports using sensors and automated functions.[43] While this technology building allows for incredible amounts of data processing, extraction, and efficiency; 5G technology also allows for data centralization; and artificial intelligence allows for easy processing and exploitation.[44]

Many believe that China is using the DSR to gain privileged access to the information of millions of consumers, giving Beijing major surveillance opportunities. Under China’s 2017 National Intelligence Law, Huawei is legally required to conduct intelligence work on behalf of the Chinese government.[45] Thus, “the Chinese government has the ability to use Huawei-built 5G networks to collect intelligence, monitor critics, steal intellectual property, and disable networks.”[46]

Thus, the U.S. and many of its allies have questioned the efficacy of employing Huawei’s technology, fearing the hidden dangers of Chinese surveillance, hacking, and AI data collection.[47] Australia, Japan, the US, and the UK have outright banned Huawei technology, and many other countries have created significant hurdles to prevent Huawei from being their sole 5G network provider.[48] Meanwhile, according to Morocco’s National Telecommunications Regulatory Agency, over 500 different pieces of Huawei equipment have been approved for use in Morocco.[49]

It is difficult to understand exactly how technology implementation can impact a country’s digital ecosystem because many aspects of the telecom business, including the details of network infrastructure, equipment, and how it functions can be extraordinarily complicated. For example, AI computer chip technology packs up to sixty billion transistors, and nearly 1,500 processing units on a single chip. [50] Digital software consists of millions of lines of complex code. This means that technology and digital infrastructure systems can be “blind” products upon purchasing. It is difficult, if not impossible, to know all of a product’s capabilities, or whether there are security vulnerabilities embedded within.

A review conducted by The Washington Post of more than 100 Huawei PowerPoint presentations, many of which were marked “confidential,” suggests that the company has had a much more significant role in conducting surveillance for the Chinese Communist Party (CCP) than it has acknowledged.[51] These marketing presentations showed Huawei “pitching how its technologies can help government authorities identify individuals by voice, monitor political individuals of interest, manage ideological reeducation and labor schedules for prisoners, and help retailers track shoppers using facial recognition.”[52] By acting as network administrators, legally bound to the CCP, Huawei will have access to data streams in real-time across its networks around the world, enabling them to develop influence and power over host nations.

For example, in 2018 it was reported that the IT network of the Chinese-built African Union headquarters in Ethiopia was compromised, and data was being sent directly to Shanghai for five years.[53] This data was procured using Huawei security cameras and data networks.[54] While the building was initially considered, “a gift from China to the friends of Africa,” journalists from Le Monde determined that Chinese engineers deliberately left two digital “backdoors” that allowed Chinese hackers to access the organization’s internal exchanges discreetly.[55] The African Union has since acquired its own servers and declined China’s offer to configure them.[56] Although this may be considered pragmatic spycraft for China, the vulnerabilities of Chinese-built infrastructure and technology systems are undeniable, and the information China obtained likely gave them major strategic advantages over African Union nations.

By building core infrastructure in Morocco, Huawei has positioned itself to win subsequent network upgrade contracts and provide complimentary services in contracting countries.[57] Chinese dominance in essential infrastructure systems such as cell networks, port technology, and railway communication systems can leave still leave the country vulnerable to economic coercion and make defense strategies with allied countries difficult, as communication systems would be assumed to be compromised.[58]

However, there has been significant disapproval of the “digital trench warfare” that has developed during this technology “arms race.”[59] Many European Union countries do not believe the Chinese digital security threat is supported by evidence.[60] Further, the U.S. and other western allies critical of Chinese technological ambition cannot provide an equivalent alternative.[61] German Interior Minister Horst Seehofer stated that Germany opposes exclusion of Huawei from its 5G construction because it would take 5 to 10 additional years without Huawei participation.[62]Chinese scholars purport that the Chinese approach to digital development is in contrast to the West, which “stresses the commercial and enterprise-led side of development” while China has been seeking an approach that “respects the national conditions and autonomy of African countries, which aims to… open up new space for African countries to accelerate their development with greater momentum.”[63] China may be able to share the dividends of digital transformation with their African partners, while improving host nation’s digital capabilities and helping them get on the fast track in the digital economy field.[64]

It may be instructive to examine how China employs its technologies within its own borders. The very design of its computer software has been adapted for internal surveillance of its people, unrivaled in its depth and extent.[65]China’s Party publication, People’s Daily, stated that the country’s facial recognition system could scan the faces of China’s 1.4 billion citizens in just one second.[66] Using security cameras and artificial intelligence, government databases can then filter through millions of citizens’ registration pictures to identify individuals.^[67] The Chinese internet is also highly censored, and information is suppressed to monitor and ensure adherence to CCP policies.[68] Thus, it would be counter-intuitive to assume such capabilities would not be used to benefit China when implemented abroad, especially in the event of a geopolitical crisis wherein such systems and intelligence would be decisive.

Lastly, China is now adding arbitration clauses to its BRI and DSR contracts.[69] These clauses require partnering nations to conduct legal proceedings in Chinese courts, in accordance with Chinese civil law, in the Chinese language, and with judges drawn from Chinese courts.[70] While China claims these courts will establish a standardized dispute resolution system across its BRI and DSR projects to avoid the “complicated, time-consuming, and costly” use of local courts and international arbitration, it is reasonable to consider this a strategic move to protect Chinese interests.[71]

 

Geopolitical Implications

Chinese Communist Party (CCP) Leader Xi Jinping has made his intentions with the BRI and DSR clear. While publicly emphasizing China’s commitment to economic liberalization, to members of the CCP, he has stressed the need to “tighten the dependence of the international industrial chain on China.”[72] Morocco’s geographic location makes it a valuable relay point between Africa and Europe for China. Zhang Yuyou, and associate professor in the Institute of Middle Eastern Studies at China’s Northwest University, said, “In the past, China’s cooperation in the region was mainly with resource-rich countries, but Morocco is an exception… Morocco is China’s important potential bridgehead in the Mediterranean.”[73] Now that Morocco has officially joined the BRI, it is likely that Chinese investment will continue to increase.

Like many other developing nations, Morocco has shown a preference for China’s stated noninterference policies. Unlike western partners, China promises both digital and political sovereignty.[74] However, non-interference and neutrality may not always be in China’s best interest. The more involved China becomes with its partners, the more pressure partners may face to take sides on disputed issues. For example, Morocco’s regional dispute with Algeria over the Western Sahara region may be analogous to Chinese sentiment regarding Hong Kong or Taiwan.

Examples of China “translating” economic influence over countries into political leverage include: pressuring Cambodia to block resolutions critical of Chinese practices in the South China Sea; placing restrictions on Norwegian salmon after the Nobel Peace Prize was awarded to a Chinese dissident, and successfully pressuring Greece and Hungary to block the EU from condemning China at the UN Human Rights Council.[75] When Australia suggested that COVID-19 may likely have originated from China, Beijing levied tariffs on a dozen Australian products and ordered traders to stop buying Australian commodities.^[76] As China faced global criticism for their internment of its Uyghur Muslim minority, Pakistan–which has the world’s second-largest Muslim population and is the largest recipient of BRI funds–has remained publicly silent on the issue.[77]

In December of 2021, the Moroccan Court of Cassation made the decision to allow the extradition of an Uyghur Muslim man to China. According to Dr. Dilnur Reyhan, head of the Uyghur Institute, “Morocco has held Idris Hasan since July [2021]…despite the absence of any proof, only to please China.”[78] While the weight the evidence against Hasan is up to debate, under international law no state has the right to expel, return or otherwise remove any individual from its territory whenever there are “substantial grounds” for believing that the person would be in danger of being subjected to torture or other human rights violations in the State of destination.[79] Morocco has since decided to halt the extradition decision, despite their 2017 extradition agreement with China, because the man was believed to be at risk of arbitrary detention, torture, or other cruel punishment.[80] Thus, despite the initial ruling, this may be an indicator of Morocco’s resilience to Chinese pressure in the political sphere.

In addition to the examples described above, there are discrete instances which policymakers should consider when assessing the potential consequences of adopting Chinese technology long-term.

 

·      Cyberwarfare

Moroccan policymakers must assess the risks associated with long-term reliance on Chinese technology and digital infrastructure. Russia’s recent use of cyberwarfare in Ukraine has given the world a preview of the effectiveness of power in the digital sphere. Before invading the Crimean Peninsula, Russian hackers turned off electric power for approximately 230,000 customers in western Ukraine.[81] Before Russia invaded in 2022, Ukraine was hit by a “never-before-seen” malware designed to wipe data, on a “different level” from previous attacks.[82] A UK newspaper, The Times, recently obtained a report from Ukraine’s security service (SBU) which implicates Chinese complicity in the cyberattacks. An SBU source told The Times that “China’s attacks sought to infiltrate targets ranging from border defence forces to the national bank and railway authority. They were designed to steal data and explore ways to shut down or disrupt vital defence and civilian infrastructure.”[83] This suggests that vulnerabilities in the digital sphere may be the first to be exploited when a foreign country is deeply embedded in a host nation’s digital infrastructure, and China’s promises of digital sovereignty may be malleable in times of conflict.

 

·      Potential Conflict

Given the unpredictability of the war taking place in Ukraine at the time of writing, the threat of a divisive international conflict should not be disregarded. For example: while Morocco’s relationship with China is still in its early stages, China has had a strong and profitable relationship with Algeria for decades.[84] When Chinese diplomats were questioned about their position on the Western Sahara region, they stated that they will align themselves with the UN position.[85] Currently, the UN position is that the Western Sahara region is not a legal part of Morocco, but Morocco is considered the administrative authority there.[86] Most, if not all, Moroccans will disagree. Thus, if a conflict were to occur, China would likely have to take a side, and it may not side with Morocco. Any surveillance capabilities, digital infrastructure control, or economic leverage that China possesses in a host nation would be pivotal in a time of conflict. While Morocco’s economic diversification strategies are effective when bargaining with western allies, relying on foreign digital infrastructure creates significant vulnerabilities.

 

Conclusion: Risk vs. Reward

            The implementation of Morocco’s Digital 2025 plan is a key component to the country’s future development. It appears the Chinese BRI and DSR initiatives would aid and accelerate development through advantageous capital investment in critical infrastructure and technology. Furthermore, an economic relationship with China allows Morocco to negotiate more effectively with European partners. As Morocco continues to create additional opportunities for foreign investors, increased competition results in greater bargaining power for Morocco.

Other nations’ experiences with BRI/DSR developments have enjoyed mixed success.[87] Some have resulted in infrastructural triumphs, and others have resulted in Chinese use of leverage.[88] It seems that a distinct dichotomy exists between the transparent risks and benefits of physical BRI infrastructure projects, and those of the DSR, which are opaque and hidden behind the complexities of its technologies. In sum, the pervasive and blind nature of Chinese technology systems may compromise national and personal information in service to China’s intelligence interests.

            However, Morocco has demonstrated its independence in that both its private companies and policymakers are not easily persuaded by Chinese projects that don’t work towards Morocco’s long-term goals.[89] Thus, it is advisable for Moroccan policymakers to continue to make a concerted effort to avoid long-term reliance on Chinese technologies. In the event of a major political strife, or otherwise, China may hold a substantial amount of leverage over Morocco if it continues to rely on Chinese technology. It may be advantageous to: (1) put mandatory lease limits on Huawei equipment, which would force companies to avoid permanent reliance on Chinese tech when licenses expire;[90] (2) create incentives to attract a diverse group of telecom companies in Morocco, to avoid reliance on a single technology manufacturer; and (3) continue to phase-out foreign data center reliance, which will allow Morocco to maintain control of its soon-to-be most valuable resource: data.

 

Footnotes

[1] Zhao, Ben, Morocco belt and road deal could give China gateway to Mediterranean, experts say, South China Morning Post (Jan. 8, 2022),https://www.scmp.com/news/china/diplomacy/article/3162587/morocco-belt-and-road-deal-could-give-china-gateway.

[2] Malik, Ammar A., et al., Banking on the Belt and Road: Insights from a new global dataset of 13,427 Chinese development projects, AidData (Sept. 2021) at 3, https://www.aiddata.org/publications/banking-on-the-belt-and-road.

[3] Brautigam, Deborah, Huang Yufan, & Acker, Kevin, Risky Business: New Data on Chinese Loans and Africa’s Debt Problem, China Africa Research Initiative (2020) No.3 at 2. https://static1.squarespace.com/static/5652847de4b033f56d2bdc29/t/6033fadb7ba591794b0a9dff/1614019291794/BP+3+-+Brautigam%2C+Huang%2C+Acker+-+Chinese+Loans+African+Debt.pdf. In 2014, a year after the peak of Chinese lending commitments in Africa, the International Monetary Fund predicted that sub-Saharan Africa would continue to grow at a rate of 5.5%. COVID-19, among other factors, have slowed this growth. However, Chinese investment has still been key in building essential infrastructure such as roads, electrical grids, and airports, across the continent, boosting the economy in pivotal industries.  

[4]Chinese Loans to Africa Database, China Africa Research Initiative, http://www.sais-cari.org/data; China’s Belt and Road Implications for the United States, Council on Foreign Relations, Independent Task Force Report No. 79 (Mar. 23, 2021), at 36, 87, 97, https://www.cfr.org/belt-and-road-initiative. 

[5] Yong, Huang, Construction of Digital Silk Road lights up BRI cooperation, People’s Daily (April 24, 2019), http://en.people.cn/n3/2019/0424/c90000-9571418.html.

[6] Id.

[7] Motolani Agbebi, China’s Digital Silk Road and Africa’s Technological Future, Council on Foreign Relations (Feb. 1, 2022), https://www.cfr.org/blog/chinas-digital-silk-road-and-africas-technological-future.

[8] Hillman, Johnathan, Influence and Infrastructure: The Strategic Stakes of Foreign Projects, Center for Strategic and International Studies (January 22, 2019), http://csis.org/ analysis/influence-and-infrastructure-strategic-stakes-foreign-projects.

[9] See Jones, Lee & Hameiri, Shahar, Debunking the Myth of ‘Debt-trap Diplomacy’, Chatham House (Aug. 19, 2020), https://www.chathamhouse.org/2020/08/debunking-myth-debt-trap-diplomacy.

[10] Lafargue, François, The Economic Presence of China in the Maghreb: Ambitions and Limits, Fondation pour la recherche stratégique (Oct. 29, 2018), https://www.frstrategie.org/en/programs/observatoire-du-monde-arabo-musulman-et-du-sahel/economic-presence-china-maghreb-ambitions-and-limits-2018; Zoubir, H. Yahia, Expanding Sino-Maghreb Relations, Chatham House (Feb. 26, 2020), https://www.chathamhouse.org/2020/02/expanding-sino-maghreb-relations/4-tunisia-and-china-evolution-relations.

[11] Feuer, Sarah and Ayadi, Reda, Twenty Years Under King Mohammed VI (Part 2): Foreign Policy Developments, Policy Watch 3157 (July 29, 2019), https://www.washingtoninstitute.org/policy-analysis/view/twenty-years-under-king-mohammed-vi-part-2-foreign-policy-developments; Zoubir, H. Yahia, Expanding Sino-Maghreb Relations, Chatham House (Feb. 26, 2020), https://www.chathamhouse.org/2020/02/expanding-sino-maghreb-relations/4-tunisia-and-china-evolution-relations.

[12] Feuer and Ayadi, supra note 8.  

[13] Luedi, Jeremy, Under the Radar: What’s behind China’s love affair with Morocco?, Global Risk Insights (March 26, 2017), https://globalriskinsights.com/2017/03/chinas-love-affair-with-morocco; The multibillion-dollar Noor 2 and Noor 3 solar farm near Ouarzazate, 60 miles southeast of Marrakesh, the biggest solar park ever built; although Noor 1 has been operating since 2016, it is expected to be completed in 2019.

[14]Feuer and Ayadi, supra note 8.

[15] See e.g. Huawei to set up regional logistics centre in Tanger Med port, PortsEurope (Sept. 7, 2018), https://www.portseurope.com/huawei-to-set-up-regional-logistics-centre-in-tanger-med-port/; Tangier: King Mohammed VI Launches $1 Billion Chinese Investment Project,” Morocco World News (Mar. 20, 2017), https://www.moroccoworldnews.com/2017/03/211612/tangier-king-mohammed-vi-launch-largest-chinese-investment-project-north-africa/; Casablanca Finance City signs a partnership with the Chinese Financial Center of Beijing, Casablanca Finance City (July 5, 2018), https://casablancafinancecity.com/communique-de-presse-en/casablanca-finance-city-signs-a-partnership-with-the-chinese-financial-center-of-beijing/?lang=fr.

[16]Id.

[17]AidData’s Global Chinese Development Finance Dataset, Version 2.0, AidData, https://www.aiddata.org/china-development-finance#map.

[18] Id.

[19] See AidData, Project ID: 2065, https://china.aiddata.org/projects/2065/; AidData, Project ID 30947, https://china.aiddata.org/projects/30947/.

[20]The world’s most valuable resource is no longer oil, but data, The Economist (May 6, 2017), https://www.economist.com/leaders/2017/05/06/the-worlds-most-valuable-resource-is-no-longer-oil-but-data.

[21] Yupei, Huang, China-Africa Joint Endeavor on the Digital Silk Road: Opportunities, Challenges and Approaches, China International Studies(September/October 2020).

[22] His Majesty King Mohammed VI Speech to the African Union Extraordinary Summit on Continental Free Trade Area, (March 21, 2018), https://www.maroc.ma/en/news/au-extraordinary-summit-african-continental-free-trade-area-kicks-kigali-participation-morocco.

[23] Bridging the Gap: Matching the Digital Skills and The Employability Pipeline in Morocco, Digital Talent Review- A Huawei Initiative (2021).

[24] Tugendhat, Henry and Voo, Julia, China’s Digital Silk Road in Africa and the Future of Internet Governance, China Africa Research Initiative, Policy Brief No. 60 (2021), at 2.

[25] Huawei to construct a regional logistics center in Morocco, Africa Telecom Review (Sept. 13, 2018), https://www.telecomreviewafrica.com/index.php/en/articles/telecom-vendors/1224-huawei-to-construct-a-regional-logistics-center-in-morocco; Huawei Boosts Digital Speed for Morocco Rails, Huawei (April 4, 2022), https://e.huawei.com/en/case-studies/global/2017/201704221416; Huawei Ready to Cooperate with Moroccan Partners to Launch 5G Network, The North Africa Post (Jan. 21, 2020), https://northafricapost.com/37192-huawei-ready-to-cooperate-with-moroccan-partners-to-launch-5g-network.html.

[26]Broadband Experiences in Selected Countries, World Bank Group, https://ddtoolkits.worldbankgroup.org/broadband-strategies/global-footprints/broadband-experiences-selected-countries, Broadband penetration is defined as the number of subscriptions to fixed and mobile broadband services, i.e. with advertised data speeds of 256 kbps or more, divided by the number of residents in each country.

[27] Digital Talent Review- A Huawei Initiative, supra note 20.

[28] Creating Markets in Morocco: Country Private Sector Diagnostic, World Bank Group (2019), https://www.ifc.org/wps/wcm/connect/publications_ext_content/ifc_external_publication_site/publications_listing_page/cpsd-morocco.

[29]Qattab, Tarik, Investigation. Videos. Brain Drain: How Canada and Especially France are Bleeding Morocco of its Executives, Le360 (Oct. 24, 2019), https://fr.le360.ma/economie/enquete-videos-fuite-des-cerveaux-comment-le-canada-et-surtout-la-france-saignent-le-maroc-de-ses-201023.  

[30]Digital Talent Review- A Huawei Initiative, supra note 20.

[31] Maidment, Gary, Orange Morocco Winning with Wireless, HuaweiTech, https://www.huawei.com/en/technology-insights/publications/winwin/33/orange-morocco-winning-with-wireless.

[32] Digital Talent Review- A Huawei Initiative, supra note 20, at 6.

[33] Tugendhat, Henry, How Huawei Succeeds in Africa, China Africa Research Initiative, China Africa Research Initiative, Policy Brief No. 41 (2020), https://static1.squarespace.com/static/5652847de4b033f56d2bdc29/t/5e73a9cddd18b9610af5420f/1584638413829/PB+41+-+Tugendhat+-+Huawei+Kenya+Nigeria.pdf.

[34]Digital Talent Review- A Huawei Initiative, supra note 20, at 14.

[35]Kemboi, Linus, Morocco beings construction of new tech city in Tangier, Construction Review Online (Aug. 15, 2021),https://constructionreviewonline.com/news/morocco-begins-construction-of-new-tech-city-in-tangier/.

[36]Tritto, Angela & He, Yujia, Cities in China’s BRI: Green and Smart of Gray and Clumsy?, Italian Institute for International Political Studies(Nov. 27, 2020), www.ispionline.it/it/pubblicazione/cities-chinas-bri-green-and-smart-or-gray-and-clumsy-26858.

[37]Feldstein, Steven, When It Comes to Digital Authoritarianism, China Is a Challenge— But Not the Only Challenge, War on the Rocks (Feb. 12, 2020), http:// warontherocks.com/2020/02/when-it-comes-to-digital-authoritarianism-china- is-a-challenge-but-not-the-only-challenge.

[38]Construction Review Online, supra note 32.

[39]Id.

[40]Id.

[41]Id.

[42]Hemmings, John, Reconstructing Order: The Geopolitical Risks in China’s Digital Silk Road, Asia Policy 15, no. 1 (January 2020), at 7, http://nbr.org/publication/ reconstructing-order-the-geopolitical-risks-in-chinas-digital-silk-road.

[43]Smart Ports: Increasing Efficiency and Cutting Costs, Ship Technology (June 19, 2018), http://ship-technology.com/features/smart-ports-increasing-efficiency-cutting-costs.

[44] Hemmings, John and Cha, Patrick, Exploring China’s Orwellian Digital Silk Road, National Interest (Jan. 7, 2020), http://nationalinterest.org/feature/ exploring-china’s-orwellian-digital-silk-road-111731.

[45]National Intelligence Law of the People’s Republic, Chinese National People’s Congress Network, adopted June 27, 2017, https://cs.brown.edu/courses/csci1800/sources/2017_PRC_NationalIntelligenceLaw.pdf.

[46] China’s Belt and Road Implications for the United States, Council on Foreign Relations, Independent Task Force Report No. 79 (Mar. 23, 2021), at 72, https://www.cfr.org/belt-and-road-initiative. 

[47] Nakashima, Ellen, U.S. Pushes Hard for a Ban on Huawei in Europe, But the Firm’s 5G Prices Are Nearly Irresistible, Washington Post (May 29, 2019), http://washingtonpost. com/world/national-security/for-huawei-the-5g-play-is-in-europe–and-the-us-is- pushing-hard-for-a-ban-there/2019/05/28/582a8ff6-78d4-11e9-b7ae- 390de4259661story.html.

[48] Whalen, Jeanne, U.S. campaign against Huawei appears to be working, as Chinese tech giant loses sales outside its home market, The Washington Post (March 31, 2021), https://www.washingtonpost.com/technology/2021/03/31/impact-us-campaign-against-huawei/[https://perma.cc/8SPS-FJY8]; Sacks, David, China’s Huawei is Winning the 5G Race. Here’s What the United States Should Do to Respond, Council on Foreign Relations (March 29, 2021), https://www.cfr.org/blog/china-huawei-5g.

[49]Approved Equipment List, Agence Nationale de Réglementation des Télécommunications (March 1, 2022), http://www.anrt.ma/e-services/agrements-des-equipements/consulter-la-liste-des-equipements-agrees.

[50] Rosenberg, Niklas, What Does It Mean To Have 60 Billion Transistors In a Computer Chip? (July 15, 2020), https://niklasrosenberg.com/blog/2020/7/15/what-does-it-mean-to-have-60-billion-transistors-in-a-computer-chip.

[51] Dou, Eva, Documents link Huawei to China’s surveillance programs, The Washington Post (Dec. 14, 2021), https://www.washingtonpost.com/world/2021/12/14/huawei-surveillance-china/.

[52] Id.

[53] Kadiri, Ghalia & Joan Tilouine, In Addis Ababa, the headquarters of the African Union spied on by Beijing, Le Monde (Jan. 6, 2018),https://www.lemonde.fr/afrique/article/2018/01/26/a-addis-abeba-le-siege-de-l-union-africaine-espionne-par-les-chinois_5247521_3212.html.

[54] Id.

[55]Id.

[56]Id.

[57] The Chinese Company Huawei invests in the Moroccan Desert, Rue20 (May 31, 2021), https://rue20.com/512512.html; Huawei intends to launch 5G services from Morocco to Africa…and ONCF is among the collaborators, Alyaoum24 (Jan 25, 2020), https://alyaoum24.com/1370756.html.

[58] Council on Foreign Relations, supra note 42, at 111.

[59] Zhao Minghao, US Perception of and Response to the Digital Silk Road, China Int’l Studies (Sept./Oct. 2020), http://www.cnki.net; Annegret Bendiek et al., Preventing Digital Trench Warfare between the EU and China, German Institute for International and Security Affairs, (Jan. 3, 2019), https://www.swp-berlin.org/en/point-of- view/2019/preventing-digital-trench-warfare-between-the-eu-and-china/.

[60] Id.; Federica Russo, Virus Crisis Will Open Doors to Huawei 5G in Europe, Asia Times (April 30, 2020), https://asiatimes.com/2020/04/virus-crisis-will-open-doors-to-huawei-5g-in-europe/.

[61] Minghao, supra note 59 at 93.

[62] Id.; Pavlovska, Elena, Germany’s Interior Minister Oppose Huawei Exclusion, New Europe, (Jan. 20, 2020), https://www.neweurope.eu/article/germanys-interior-minister-opposes-huawei-exclusion/.

[63] Huang Yupei, China-Africa Joint Endeavor on the Digital Silk Road: Opportunities, Challenges and Approaches, China Int’l Studies (Sept./Oct. 2019), http://www.cnki.net; see also, Working Together to Deliver a Brighter Future for Belt and Road Cooperation, Keynote Speech by H.E. Xi Jinping at the Opening Ceremony of the Second Belt and Road Forum for International Cooperation.

[64] Yupei, supra note 63 at 20.

[65] McGregor, Grady, The world’s largest surveillance system is growing–and so is the backlash, Fortune (Nov. 3, 2020), https://fortune.com/2020/11/03/china-surveillance-system-backlash-worlds-largest/.

[66] People’s Daily, China [@PDChina], “’Sky Net’, a facial recognition system that can scan China’s population of about 1.4 billion people in a second, is being used in 16 Chinese cities and provinces to help police crack down on crime and improve security, Twitter (Mar. 27, 2018), https://twitter.com/PDChina/status/978444380066390016.

[67] Phoebe Zhang, Privacy in China: the growth of facial recognition technology in the private sector raises concerns about security and identity, South China Morning Post (Nov. 26, 2020),  

https://www.scmp.com/lifestyle/article/3111428/privacy-china-growth-facial-recognition-technology-private-sector-raises [https://perma.cc/F772-294J].

[68] See OpenNet Initiative (ONI), China, at 271 (Aug 9, 2012), http://access.opennet.net/wp-content/uploads/2011/12/accesscontested-china.pdf.

[69] Provisions of the Supreme People’s Court on Several Issues Regarding the Establishment of the International Commercial Court, CHINA INT. COM. CT., http://cicc.court.gov.cn/html/1/219/208/210/817.html (last visited July 26, 2020), art. 2 (“The International Commercial Court accepts the following cases: (1) first instance international commercial cases in which the parties have chosen the jurisdiction of the Supreme People’s Court according to Article 34 of the Civil Procedure Law, with an amount in dispute of at least 300,000,000 Chinese yuan; (2) first instance international commercial cases which are subject to the jurisdiction of the higher people’s courts who nonetheless consider that the cases should be tried by the Supreme People’s Court for which permission has been obtained; (3) first instance international commercial cases that have a nationwide significant impact; (4) cases involving applications for preservation measures in arbitration, for setting aside or enforcement of international commercial arbitration awards according to Article 14 of these Provisions; (5) other international commercial cases that the Supreme People’s Court considers appropriate to be tried by the International Commercial Court.”).

[70] Dahlan, Malik R., Envisioning Foundations For the Law Of The Belt and Road Initiative: Rule of Law and Dispute Resolution Challenges, Harvard International Law Journal, Essay, V. 62 at 14 (2020), https://harvardilj.org/wp-content/uploads/sites/15/Envisioning-Foundations-For-the-Law-of-the-Belt-and-Road-Initiative-Rule-of-Law-and-Dispute-Resolution-Challenges.pdf. 

[71]Markell, Jacob, Dispute Settlement on China’s Terms: Beijing’s New Belt and Road Courts, Merics, (Feb. 14, 2018), http://merics.org/en/analysis/dispute-settlement- chinas-terms-beijings-new-belt-and-road-courts; Jonathan Hillman, Jonathan & Goodman, Mathew, China’s ‘Belt and Road’ Courts to Challenge Current US-Led Order, Financial Times (June 24, 2018), http://ft.com/content/b64d7f2e-8f4d-11e8-b639- 7680cedcc421; and Chandran, Nyshka, China’s Plans for Creating New International Courts Are Raising Fears of Bias, CNBC (Feb. 1, 2018), http://cnbc.com/ 2018/02/01/china-to-create-international-courts-for-belt-and-road-disputes.html.

[72] Xi Jinping, Fostering a New Development Paradigm and Pursuing Mutual Benefit and Win-win Cooperation, Xinhua (Nov. 19, 2020), http://xinhuanet.com/english/2020-11/19/c_139527192.htm; Xi Jinping, Some Major Issues of the National Medium- and Long-term Economic and Social Development Strategy (国家中长期经 济社会发展战略若干重大问题), Qiushi, (Oct. 31, 2020), http://qstheory.cn/dukan/ qs/2020-10/31/c_1126680390.htm.

[73] Zhao, Ben, Morocco belt and road deal could give China gateway to the Mediterranean, experts say, South China Morning Post (Jan. 8, 2022),https://www.scmp.com/news/china/diplomacy/article/3162587/morocco-belt-and-road-deal-could-give-china-gateway, https://perma.cc/9SKF-LDPM.

[74]Gagliardone, Iginio, The Impact of Chinese Tech Provision on Civil Liberties in Africa, South African Institute of International Affairs Policy Insights 99 (Dec. 2020), https://saiia.org.za/research/the- impact-of-chinese-tech-provision-on-civil-liberties-in-africa/.

[75] Mogato, Manuel, Martina, Michael, and Blanchard, Ben, ASEAN Deadlocked on South China Sea, Cambodia Blocks Statement, Reuters (July 25, 2016), http://reuters.com/ article/us-southchinasea-ruling-asean-idUSKCN1050F6; Milne, Richard, Norway Sees Liu Xiaobo’s Nobel Prize Hurt Salmon Exports to China, Financial Times (Aug. 15, 2013), http://ft.com/ content/ab456776-05b0-11e3-8ed5-00144feab7de; McLaughlin, Daniel, EU on Guard as China Builds Infrastructure and Influence, Irish Times (Nov. 22, 2018), http://irishtimes.com/news/world/europe/eu-on-guard-as-china-builds- infrastructure-and-influence-1.3705904.

[76] Westcott, Ben, Australia Angered China by Calling for a Coronavirus Investigation. Now Beijing Is Targeting Its Exports, CNN (May 27, 2020), http://cnn.com/2020/05/ 26/business/china-australia-coronavirus-trade-war-intl-hnk/index.html; Clark, Aaron, Varley, Kevin, and Rajesh, Kumar Singh, Stranded Coal Ships Caught in Crosshairs of China-Australia Spat, Bloomberg (Nov. 12, 2020), http://bloomberg.com/news/ articles/2020-11-12/stranded-coal-ships-caught-in-crosshairs-of-china-australia-spat? srnd=markets-vp&sref=6ZE6q2XR; Council on Foreign Relations supra note 42 at 50.

[77]A Conversation with Prime Minister Imran Khan of Pakistan, Council on Foreign Relations (Sept. 23, 2019), https://www.cfr.org/event/conversation-prime-minister-imran-khan-pakistan-0.

[78] Dr. Dilnur Reyhan (@DilnurReyhan), Twitter (Jan. 1, 2022, 8:13 PM), https://twitter.com/DilnurReyhan/status/1477357453561974790?ref_src=twsrc%5Etfw%7Ctwcamp%5Etweetembed%7Ctwterm%5E1477357453561974790%7Ctwgr%5E%7Ctwcon%5Es1_&ref_url=https%3A%2F%2Fmoroccotelegraph.com%2F2022%2F01%2F5324%2Fuyghur-activist-idris-hasan-extradition-is-suspended-by-morocco-after-un-intervention%2F.

[79] Advisory Opinion on the Extraterritorial Application of Non-Refoulement Obligations under the 1951 Convention relating to the Status of Refugees and its 1967 Protocol, https://www.unhcr.org/4d9486929.pdf.

[80] Morocco’s extradition of Uyghur asylum seeker to China could lead to serious rights violations, argue UN experts, United Nations (Dec. 16, 2021), https://news.un.org/en/story/2021/12/1108152; Morocco: Detained Uyghur must not be transferred to China, Amnesty International (Sept. 21, 2021), https://www.amnesty.org/en/latest/news/2021/09/morocco-detained-uyghur-must-not-be-transferred-to-china/#:~:text=China%20ratified%20an%20extradition%20treaty,previously%20done%20for%20Uyghur%20organizations.

[81] Miller, Christina, Throwback Attack: BlackEnergy attacks the Ukrainian power grid, Industrial Cyber Security Pulse (Nov. 11, 2021), https://www.industrialcybersecuritypulse.com/throwback-attack-blackenergy-attacks-the-ukrainian-power-grid/.

[82]Tidy, Joe, Ukraine crisis: ‘Wiper’ discovered in latest cyber-attacks, BBC News (Feb. 24, 2022), https://www.bbc.com/news/technology-60500618.

[83] Tucker, Maxim, China accused of hacking Ukraine days before Russian invasion, The Times (April 1, 2022), https://www.thetimes.co.uk/article/china-cyberattack-ukraine-z9gfkbmgf.

[84] See Ghanmi, Lamine, Algeria draws Europe’s ire by cutting imports, boosting trade with China, The Arab Weekly (April 22, 2018), https://thearabweekly.com/algeria-draws-europes- ire-cutting-imports-boosting-trade-china: “China has emerged as Algeria’s main import market, sending $8.3 billion worth of goods to the North African country in 2017.”

[85] See United Nations Security Council, “Resolution 2468 (2019)” (April 30, 2019), https://www. securitycouncilreport.org/atf/cf/%7B65BFCF9B-6D27-4E9C-8CD3-CF6E4FF96FF9%7D/S_res_2468.pdf.

[86] Simon, Sven (2014). “Western Sahara” Self-Determination and Secession in International Law. OUP Oxford.  At 262. ISBN 978-0-19-100691-3. Retrieved 8 March 2022. To sum up the legal status: Western Sahara is not a part of Morocco and Morocco has no legal title or claim to the territory. Since the annexation is illegal, it is null and void, and Morocco is therefore, legally speaking, an occupying power.”

[87] Success of China’s Belt & Road Initiative Depends on Deep Policy Reforms, Study Finds, The World Bank (June 18, 2019), https://www.worldbank.org/en/news/press-release/2019/06/18/success-of-chinas-belt-road-initiative-depends-on-deep-policy-reforms-study-finds.

[88] Frayer, Lauren, In Sri Lanka, China’s Building Spree Is Raising Questions About Sovereignty, National Public Radio (Dec. 13, 2019), https://www.npr.org/2019/12/13/784084567/in-sri-lanka-chinas-building-spree-is-raising-questions-about-sovereignty. 

[89] See e.g., Construction Review Online supra note 32; Amnesty International supra note 72.

[90]See e.g., Rosemain, Mathieu & Barzic, Gwenaelle, Exclusive: French limits on Huawei 5G equipment amount to de facto ban by 2028, Reuters (July 22, 2020), https://www.reuters.com/article/us-france-huawei-5g-security-exclusive/exclusive-french-limits-on-huawei-5g-equipment-amount-to-de-facto-ban-by-2028-idUKKCN24N26R.