If a Chinese oil company found itself on trial in a US court for conspiracy to commit human rights abuses in a third country, Beijing would not take the news well.
As China’s UN Security Council voting record suggests, it doesn’t approve of activities that threaten the autonomy of a sovereign state. A US court exercising its extraterritorial powers would be perceived as just that.
"They are not receptive to the assertion of jurisdiction beyond national borders," said Dr Jeffrey Bader, senior fellow in foreign policy studies at the Brookings Institution.
"The Chinese government’s reaction would be pretty hostile. There is no doubt that if the US courts were taking action detrimental to PetroChina, the Chinese would quickly look for a tit-for-tat."
Regardless of the independence of the US justice system, it is thought that retaliatory action would likely target the US government. Through administrative or judicial measures, key US companies – not just in the energy sector – would find themselves under the cosh.
"Suddenly they announce that a Boeing deal or Airbus deal is not going through – but they don’t give the real reason why," said Arvind Ganesan, director of the business and human rights program for Human Rights Watch.