Human Rights Watch director Kenneth Roth and National Endowment for Democracy president Carl Gershman are on the list.
China on Monday sanctioned 11 Americans, including senators Marco Rubio and Ted Cruz, in retaliation for similar US moves against Chinese officials over Beijing's crackdown in Hong Kong.
"China has decided to impose sanctions on some people that behaved badly on Hong Kong-related issues," foreign ministry spokesman Zhao Lijian said Monday, with Human Rights Watch director Kenneth Roth and National Endowment for Democracy president Carl Gershman also on the list.
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