CHINA Law and Practice Contributed by: Xing Nan (Nancy), AnJie Broad Law Firm
1. Trends and Overview 1.1 Sanctions Market
an injunction ordering the foreign company to deliver the bill of lading and to compensate for losses. 1.3 Key Industries Judging by the export control list released by the Min - istry of Commerce, the announcement on the launch of the investigation of the unreliable entity list by the working mechanism of the unreliable entity list, and the decision on taking countermeasures released by the Ministry of Foreign Affairs, the manufacturing industry has been most affected, mainly in the fields of aviation, aerospace, the military industry, artificial intelligence, and drones. 1.4 Overview 1.4.1 Types of Sanctions The types of sanctions implemented in China include: • visa restrictions; • asset seizure and restrictions; • trade and transactions restrictions; • fines; and • other necessary measures as deemed necessary by relevant Chinese authorities. 1.4.2 Scope of Sanctions China’s sanctions law does not explicitly state that it has extra-territorial effect. However, according to the relevant provisions of the Anti-Foreign Sanctions Law of the People’s Republic of China, organisations and individuals in China must comply with the anti- sanction measures prescribed by the relevant depart - ments of the General Office of the State Council of the People’s Republic of China. The organisations and individuals here do not exclude foreign entities and individuals – ie, foreign enterprises, organisations and individuals. Therefore, it can be understood that any organisation and individual in China must comply with the relevant sanctions regulations. As a result, China’s sanctions law may be considered to have extra-territorial effect. 1.4.3 Domestic and/or Supranational Measures China’s sanctions are imposed at a domestic level, empowered by domestic legislation. For example, the Anti-Foreign Sanctions Law of the People’s Repub - lic of China stipulates that China can take counter -
In 2026, the State Council of the People’s Republic of China issued the Regulations of the People’s Republic of China on Countering Improper Extraterritorial Juris - diction by Foreign States (effective 7 April 2026). These regulations stipulate that the Chinese government and relevant departments can: i) identify undue extrater - ritorial jurisdiction measures by foreign entities; ii) assess the actions of relevant countries in implement - ing such measures; iii) promote the inclusion of foreign organisations and individuals implementing or partici - pating in undue extraterritorial jurisdiction measures on a malicious entity list; and iv) decide to take one or more countermeasures and restrictive measures against them. The regulations also stipulate that if any organisation or individual implements or assists in the implementation of undue extraterritorial jurisdic - tion measures by foreign entities, infringing upon the legitimate rights and interests of Chinese citizens or organisations, Chinese citizens or organisations may file lawsuits in people’s courts in accordance with the law, demanding cessation of the infringement and compensation for losses. Furthermore, the Ministry of Commerce of China has repeatedly adjusted the controlled items. At the same time, counter-sanction enforcement activities have been very active. The Min - istry of Foreign Affairs and the Ministry of Commerce have repeatedly taken countermeasures and punitive measures to restrict activities by foreign entities that harm China’s national interests and damage the legiti - mate rights and interests of Chinese enterprises and individuals. 1.2 Key Trends China has been continuously improving its anti-sanc - tions legislation and strengthening the implementa - tion of its anti-sanctions system at law enforcement and judicial levels. The Work Report of the Supreme People ’ s Court of the People ’ s Republic of China , released in March 2026, stated that it firmly upholds the country’s judicial sovereignty and implements the Anti-Foreign Sanctions Law to effectively counter illegal sanctions and “long-arm jurisdiction”. In one instance, a foreign company refused to sign a bill of lading on the grounds that a Chinese company was sanctioned. Upon application, a Chinese court issued
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