Two countries, one system: why we must drop the pretence

[vc_row][vc_column][vc_single_image image=”115971″ img_size=”full” add_caption=”yes”][/vc_column][/vc_row][vc_row][vc_column][vc_column_text]Two countries, one system.

That, effectively, is the policy in Hong Kong and China after more than 50 pro-democracy activists were arrested yesterday morning under the National Security Law for their part in the pro-democracy primaries last July.

The primaries were held to identify pro-democracy candidates for Hong Kong’s Legislative Council (LegCo) elections which were due in September 2020.

At the time, HKSAR chief executive Carrie Lam said, “If this so-called primary election’s purpose is to achieve the ultimate goal of delivering what they called ’35+’ [lawmakers], with the objective of objecting or resisting every policy initiative of the HKSAR government, it may fall into the category of subverting the state power – one of the four types of offences under the national security law (NSL).”

Lam subsequently postponed the 2020 LegCo elections, citing a resurgence in Covid-19 and claiming support for the move from Beijing.

Lam’s threat has now materialised, with many of the candidates and organisers of the primaries now arrested for breaking the NSL.

Several of the candidates for the primaries had already fled to exile, including Nathan Law, Ted Hui and Sunny Cheung.

The three issued a joint statement saying, “This has yet again proven how the National Security Legislation tramples upon One Country, Two Systems. The indiscriminate arrest concerns political figures from all sides of the spectrum. The unprecedented scale indicates how the Communist government had decided to purge the democratic camp, silencing all dissent.”

The three said that the ambiguity of the law now threatens all 600,000 Hongkongers who cast their votes in the primaries.

Benedict Rogers, CEO of Hong Kong Watch believes the arrests mean no one in Hong Kong is safe anymore.

“The simple act of organising a primary election for the purposes of selecting candidates for the pro-democracy camp ahead of Hong Kong’s planned Legislative Council elections is now deemed an act of subversion under the draconian national security law, carrying with it the potential for years in prison,” he told Index.

“Potentially any expression of desire for democracy or dissent from the Chinese or Hong Kong governments could be a criminal act. The national security law and its vaguely defined crimes of subversion and collusion with foreign political forces, imposed on Hong Kong last July, already threatened freedom of expression in Hong Kong, and now the arrests we have seen in recent months and especially these mass arrests prove that this draconian law has destroyed freedom of expression in Hong Kong.”

The UN clearly agrees with this view that everyone now needs to be waiting for the knock at the door.

A spokesperson for the UN Human Rights Office said, “These latest arrests indicate that – as had been feared – the offence of subversion under the National Security Law is indeed being used to detain individuals for exercising legitimate rights to participate in political and public life.”

The situation all seems a very long way from what is laid out in the Sino-British Joint Declaration which promised to maintain the status quo until 2047.

Lord Patten, who was governor of Hong Kong at the time of the handover, told Sky News that the arrest of pro-democracy activists was a “further turning of the screw”.

He said, “This is a further attempt to destroy the freedoms of a city that has thrived under the rule of law. The people who have been arrested are not radicals, they have not been guilt of violence, they are lawyers, academics, social workers. [These are the] people who organised a vote to choose the best candidates for the elections which were then postponed, arguably because of Covid.”

UK foreign secretary Dominic Raab said that the mass arrest was “a grievous attack on Hong Kong’s rights and freedoms as protected under the Joint Declaration” and that “the Hong Kong and Chinese authorities deliberately misled the world about the true purpose of the National Security Law”.

Tom Tugendhat MP , chairman of the Foreign Affairs Committee, called it a “tragedy”, saying, “Eroding free speech and detaining democrats is an act of violence against the people of Hong Kong and the economy they have built.”

Chinese exiled cartoonist Badiucao expressed his sentiments over the arrests with his latest work.

The UN has also urged the authorities to guarantee the right to freedom of expression in the context of ongoing investigations, including by allowing journalists and news organisations to fully and freely exercise their legitimate functions.

The authorities seem unlikely to comply. Various Hong Kong publications were served with a search warrant asking for the contact information of primary election candidates. This led Tom Grundy, co-founder of Hong Kong Free Press who spoke on our podcast just before Christmas, to say, “Hong Kong newsrooms are not phonebooks for the police to call upon as they wish.”

Whether it was coincidence that the arrests took place on a day when the world’s attention was distracted towards the USA or not – which is not beyond the Chinese Communist Party – many have highlighted the irony.

Journalist Tony Lin spoke for many when he tweeted, “So many nuances need to be addressed, but at core what many ppl fought for in Hong Kong was EXACTLY what DC extremists trying to dismantle in the US: the right to vote.”

In their statement, Nathan Law, Ted Hui and Sunny Cheung express what many are now feeling.

“Foreign governments must reconsider whether Hong Kong should be treated differently from China,” they added. “Leaders of the free world must recognise the ambition and the despotic nature of the Chinese Communist Party.”

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The Big Noise

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Protests in motion: When films inspire rights’ movements

Films, like every kind of art, are often made purely for cinema’s sake – but sometimes they aren’t. Some of the most iconic recent films have actually played a major role in inspiring rights’ movements and protests around the world.

Ten Years, recipient of Hong Kong’s best film award on 3 April 2016, is just one of the latest examples of how cinema can side up with rights: films have often given protests momentum and a cultural reference.

Sometimes, directors have spoken out publicly in favour of protests; other times the films themselves have documented political abuses. In other cases, protesters and activists have given a film a new life, turning it into an icon for their protests on social media even against the directors’ original ideas.

Here are a few recent cases of popular films that have become symbols of rights’ movements around the world:

Ten Years

On 3 April, Ten Years was voted best film at the Hong Kong film awards, one of China’s most important film festivals – but most Chinese don’t know that, as the film is severely censored in mainland China.

Directed by Chow Kwun-Wai with a $64,500 budget, Ten Years is a “political horror” set in a dystopian 2025 Hong Kong. In the five short stories told in the film, Chow Kwun-Wai warns against the effects that ten years of Beijing’s influence would have on Hong Kong: The erosion of human rights, the destruction of local culture and heavy censorship.

According to the South China Morning Post, Ten Years was not intended to be a political film, but the political content is explosive to the extent that some critics have dubbed it “the occupy central of cinema”.

China Digital Times reports that both the film and the awards ceremony are banned in China. On Sina Weibo, China’s leading social network, the searches “Ten Years + Film Awards” (十年+金像) and “Ten Years + film” (十年+电影) are blocked from results.

Birdman

Winner of a 2015 Oscar, Birdman’s plot is not about rights or protests: The film told the story of a popular actor’s struggles years after his success impersonating a superhero.

But Mexican director’s Alejandro González Iñárritu’s acceptance speech turned it into the symbol of a protest against Mexican President Enrique Peña Nieto.

After asking for a respect and dignity for Mexican immigrants in the USA, Iñárritu said in his speech: “I want to dedicate this award for my fellow Mexicans, the ones who live in Mexico. I pray that we can find and build a government that we deserve.”

The speech came after the Mexican government declared the death of 43 students who went missing while organising a protest.

Iñárritu’s speech made Twitter erupt against Peña Nieto’s government under the hashtag #ElGobiernoQueMerecemos, “the government we deserve”.

Twitter user Guillermo Padilla said, “Now we are only missing a good ‘director’ in this country” – a play on words since “director” means both director and leader in Spanish.

In a photo, Birdman took the place of the Angel of Independence’s statue, symbol of Mexico City.

One user took it a step further, posting a “graphic description” of the effects of Iñárritu’s speech on the president.

Hunger Games

The sci-fi blockbuster Hunger Games took a life of its own in Thailand, where student demonstrators turned the protagonist’s salute into a symbol of rebellion against the ruling junta.

In the film, set in a heavily oppressed country where every year young people are forced to fight to death in a nationally televised contest, protagonist Katniss Everdeen defies the central government and inspires a rebellion against totalitarian rule. Her three-finger salute becomes the symbol of the protest.

In Thailand, students started to use the three-finger salute as a symbol of rebellion after the military government took power with a coup on 22 May 2014 and clamped down on all forms of protest, censored the country’s news media, limited the right to public assembly and arrested critics and opponents. According to The New York Times, hundreds of academics, journalists and activists have been detained for up to a month.

The Guardian reported that social activist Sombat Boonngam-anong wrote on Facebook: “Raising three fingers has become a symbol in calling for fundamental political rights.”

Since then, using the salute in public in groups of more than five people has been prohibited through martial law.

V for Vendetta

V for Vendetta holds a special place among films about freedom of speech. In 2005, it was incredibly successful bringing the themes freedom of speech and rebellion against tyranny into the mainstream media debate.

In the film, a freedom fighter plots to overthrow the tyranny ruling on Britain in a dystopian future. The mask he always wears has the features of Guy Fawkes, an English Catholic who attempted to blow up the parliament on 5 November 1605.

The mask has since become an icon. According to The Economist, the mask has become a regular feature of many protests. Among others, it has been adopted by the Occupy movement and Julian Assange, the founder of WikiLeaks.

David Lloyd, author of the graphic novel on which the film is based, has called the mask a “convenient placard to use in protest against tyranny … It seems quite unique, an icon of popular culture being used this way.”

Suffragette

In 2015, the film historical drama Suffragette inspired a protest against the government’s cuts to women services in Britain.

The film shows the struggle for women’s rights that took place in the beginning of the 20th century, when Emmeline Pankhurst led an all-women fight to gain the right to vote.

Before the movie premiere in London’s Leicester Square, activists from the feminist group Sister Uncut broke away from the main crowd, and laid down on the red carpet.

According to The Independent, they chanted “It is our duty to fight for our freedom,” and held signs reading “Dead women can’t vote” and “2 women killed every week” to draw attention to domestic violence and cuts to women’s services.

One protester told The Independent“We’re the modern suffragettes and domestic violence cuts are demonstrating that little has changed for us 97 years later.”

What the US closure of global media means for freedom of speech in Asia

This article first appeared in Volume 54, Issue 2 of our print edition of Index on Censorship, titled Land of the Free?: Trump’s war on speech at home and abroad, published on 21 July 2025. Read more about the issue here.

Kyaw Min Htun, a Burmese editor and reporter, moved from his home in Myanmar to the USA more than 20 years ago, seeking a place where he could finally report freely. For two decades, the USA provided that, allowing him to secure various roles at Radio Free Asia (RFA), which is based in Washington DC. On 15 March, however, that all changed.

Alongside about 75% of his US-based colleagues, Htun was told not to go into work. His job was one of thousands of casualties of president Donald Trump’s sweeping cuts to government-backed initiatives.

“Our hands are tied and we cannot do our jobs,” Htun, who was deputy director of RFA when he was furloughed, told Index.

At the beginning of May, RFA announced it would be terminating the contracts of more than 90% of its US-based staff and shutting down several language services. Days later, this move was delayed due to an administrative stay from the courts.

On 14 March, Trump had signed an executive order to stop federal funding to the US Agency for Global Media (USAGM), which oversees US-funded international media. It came amid a broader assessment by the State Department of all overseas spending that has so far led to the termination of the country’s support for more than 80% of the global aid projects it had backed.

USAGM financially supports RFA and other media platforms including Voice of America (VOA), Radio Free Europe/Radio Liberty (RFE/RL), Office of Cuba Broadcasting and the Middle East Broadcasting Networks. Its aim – since its inception with VOA in 1942 to counter Nazi propaganda as a form of soft power – has always been “to inform, engage and connect people around the world in support of freedom and democracy”. Collectively, USAGM outlets have created news in 64 languages, reaching 427 million people each week.

In many countries, such outlets are a lifeline, offering a window into what’s happening at home and abroad amid wars and famines, disasters and conflicts.
RFA – which was broadcasting in nine languages in China, Myanmar, Vietnam, Laos, Cambodia and North Korea – has been a fixture in Asia’s media landscape since 1996, when it was established to counter propaganda. It has won awards for covering under-reported issues, including the plight of North Korean escapees, the impact of the civil war in Myanmar and the treatment of the Uyghurs.

The Trump administration, however, sees VOA and RFA as “radical propaganda”, and what it calls “anti-Trump content”.

Elon Musk – the tech billionaire and, at the time, a senior adviser to the president – said on his social media platform X that RFA and RFE were made up of “radical left crazy people talking to themselves while torching $1billion [a] year of US taxpayer money”.

While support for some outlets could resume amid several lawsuits that have been lodged against USAGM and the government, many are worried about the ramifications already being felt by journalists, citizens and democracy as a whole in Asia.

The fallout

Aleksandra Bielakowska, director of advocacy and assistance at Reporters Without Borders (RSF), told Index that many of RFA’s regional reporters were journalists working in exile or underground in places such as Cambodia or Myanmar.

Journalists including Mech Dara, who exposed trafficking and scam compounds in Cambodia, and Sai Zaw Thaike, who reported on the mistreatment of inmates inside Myanmar prisons, are being persecuted by their governments. These journalists operate clandestinely to ensure stories from their countries are told, free from state influence.

The funding cut meant RFA had to sever the contracts of most of its local freelancers, exposing them in a region where press freedom is rapidly in decline. Myanmar, China, North Korea and Vietnam are among the top 10 worst countries for journalist safety. Last year, 20 journalists were killed in Asia (up from 12 in 2023) and 30% of global arrests of journalists took place on the continent.

Several efforts are being made to curtail media freedoms in countries across Southeast Asia in particular, said Bryony Lau, deputy Asia director at Human Rights Watch.

Vietnam is one of the world’s worst jailers of journalists; in Tibet, the Chinese government forbids foreign media from entering; and in Hong Kong, since the adoption of Beijing’s National Security Law in 2020, many outlets have been forced to close and their journalists arrested on national security charges.
Bielakowska said there was currently little protection available for journalists in the region, and the situation could get worse when “authoritarian regimes […] don’t see any opposition from democratic countries”.

Certain authoritarian leaders celebrated the USA’s abandonment of such publications, said Lau. Cambodia’s leader Hun Sen praised Trump on Facebook for combating “fake news”, while Global Times, part of China’s state media, lauded the cuts, claiming “almost every malicious falsehood about China has VOA’s fingerprints all over it”.

“This just tells you actually how impactful that reporting really was,” Lau said, adding that the US cuts had made the work of restricting media freedoms by these governments much easier.

“Press freedom is definitely on the retreat, and what comes in its place is never anything great,” said Rohit Mahajan, chief communications officer at RFA.

A lack of safety globally

Back in the USA, reporters’ jobs are at risk. RFA has put the majority of its staff in its headquarters on leave and VOA has had to furlough 1,300 staff, the majority of whom are journalists.

Washington-based Htun, although among those affected, considers himself lucky. With US citizenship – he sought political asylum in 2005 – he can remain in the country, but many of RFA’s team come from Asia and their US visas are reliant on their work status. For some, the prospect of returning home – potentially to a country such as Cambodia or China where they may have helped to highlight human rights abuses – is a dangerous one.

“With the current administration’s policies, it is very hard to say they are safe even if they apply for asylum here, because they could be denied any time and they could be deported,” said Htun. “This is an unprecedented, man-made disaster.”

Aside from the threat of deportation, the furloughed staff are now not earning and are scrambling to find work. They are among thousands in the capital who have lost their jobs since the wave of executive orders, which have seen other government departments closed or drastically reduced in size.
This means that competition for jobs is fierce, said Htun. The USAGM Employee Association is collating donations to support journalists affected.

Information black holes

Aside from the impact on the safety of journalists, the shuttering of these media platforms, or even just a reduction in their content, impacts the public, limiting information.

It creates a “black hole of information”, said Bielakowska, who added that this would certainly be the case in countries such as Laos and Tibet, which are more closed. In countries with strict authoritarian regimes, VOA and RFA are often the only accessible forms of information other than state-sponsored or heavily-censored media.

This will lead to “a dramatic turning off of a pipeline of accurate and independent news stories about what is happening within authoritarian states”, said Joshua Kurlantzick, senior fellow for Southeast Asia and South Asia at the Council on Foreign Relations. “There isn’t as good a source in Lao, Khmer, Vietnamese, Tibetan as RFA. People will lose touch with the real world.”

Many in Myanmar – where a civil war has raged since 2021 and the military has shut down internet access in parts of the country – rely on shortwave radio for information on the war and wider events, such as the destructive earthquake in March. While the BBC and VOA are available, only a portion of their content focuses on Myanmar whereas 100% of RFA Burma’s content is focused on the country, said Htun. He explained that a content vacuum gave the Myanmar military junta an opportunity to exploit the situation by sharing their own propaganda and misinformation.

Samady Ou, an American-Cambodian activist and youth ambassador for Khmer Movement for Democracy, cannot go home to Cambodia because his democracy work has put a target on his back. He said that there was no reliable media outlet in the country without VOA and RFA.

“Right now, in Cambodia, we don’t have any news medium left that is independent and not pro-government,” he said. “When there’s unjust goings on like land grabs or Chinese big companies coming in taking away land, [Cambodians] have no voice at all.”

US pro-democracy organisation Freedom House ranks Cambodia as “not free” as a result of a “severely repressive environment” driven by the Cambodian People’s Party which “has maintained pressure on the opposition, independent press outlets and demonstrators with intimidation, politically motivated prosecutions and violence”.

Looking ahead

Experts hope the funding cut is only temporary and the USA will see the value in supporting regional media.

Historically, USAGM has always enjoyed strong bipartisan support from Congress across every administration, explained Mahajan, calling these platforms “unique tools in America’s soft power”.

Most USAID funding in Asia has been directed towards peace and security projects, indicating that this has historically been a vested interest for the USA.

“I think there’s a consensus inside of the Congress, even right now, that China and authoritarian regimes are one of the biggest challenges of the USA, and without the right information, freedom of the press and access to reliable information, we’ll have no updates about these countries, and these countries will also manage to spread their model of information inside of Asia, which is a direct threat to the USA itself,” said Bielakowska. Whether the new administration can be convinced of this is yet to be seen.

In the meantime, RFA has filed a lawsuit, claiming the government is unlawfully withholding funds and that only Congress can fund or defund an organisation it has created.

“We are trying to keep RFA afloat as we pursue a legal challenge to the termination of our grant, which we believe is unlawful,” Mahajan said. RFE and the Middle East Broadcasting Networks have also filed lawsuits.

In April, the US District Court for the District of Columbia granted an injunction to restore funding to USAGM, but the government is yet to release the funds. Htun predicts that the legal process will wage on for months to come, potentially escalating to the Supreme Court.

“This drama could take longer than expected – probably two or three more months,” he said.

During that time, journalists will remain out of work and exposed while citizens across Asia will be far less informed.

But there is always a chance that other funders could be found for these media platforms.

“Other states and entities and private organisations could fill some of the gaps in funding for media outlets,” said Kurlantzick, who called on powerful countries in the region to stand up for media freedom by committing more funds.

Lau said it was in the interests of other concerned governments to have access to reliable information, as well as to the private sector operating in some of these countries.

Such is the public support for these media sources that Ou believes the public in Asian countries may also crowdfund to keep them functioning.

In the meantime, Bielakowska is confident that RFA and VOA are used to operating in fragile situations.

“Even with this blow, I still hope that they can continue working on the ground and find ways to support themselves.”

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