Sanctions 2026

CHINA Law and Practice Contributed by: Xing Nan (Nancy), AnJie Broad Law Firm

Republic of China or national sovereignty, security, or social public interests, it shall rule not to recognise and enforce it. On 8 November 2024, the Anti-Money Laundering Law of the People’s Republic of China was revised and passed, and was implemented on 1 January 2025. On 21 March 2025, Provisions for the Implementa - tion of the Anti-Foreign Sanction Law of the People’s Republic of China were passed and were implement - ed on 23 March 2025. On 28 October 2025, the revised Cybersecurity Law of the People’s Republic of China was adopted, com - ing into effect on 1 January 2026. Article 77 of the law stipulates that any foreign institution, organisation or individual that engages in activities endangering the cybersecurity of the People’s Republic of China shall be held legally liable; if serious consequences result, the public security department and relevant depart - ments of the State Council may also decide to freeze the assets or take other necessary sanctions against the institution, organisation or individual. On 7 April 2026, the Regulations of the People’s Republic of China on Countering Improper Extrater - ritorial Jurisdiction by Foreign States were adopted and came into effect on 7 April 2026. 3.2 Future Developments China has been active in refining its export control laws and implementing anti-sanctions measures to protect its national interests and the legitimate rights and interests of its companies. The introduction of the Unreliable Entity List is a strategic move to counter - act measures that harm Chinese companies. China will continue to formulate necessary administrative regulations and departmental rules, establish corre - sponding work systems and mechanisms, strength - en departmental co-ordination, and determine and implement relevant countermeasures and restrictive measures against actions that endanger China’s sov - ereignty, security, and development interests. Clients looking to do business in China should closely monitor these trends and work with legal and trade compliance experts to navigate the complex land -

scape of international sanctions and trade controls. It is also important to engage in proactive risk manage - ment and to be prepared for the potential impacts of sanctions on business operations.

4. Delisting Challenges 4.1 Process

According to the Provisions on the Unreliable Entity List, a correction deadline can be set for foreign enti - ties included in the list of unreliable entities, during which no sanction measures will be taken. Foreign entities could be removed from the list of unreliable entities if they correct their behaviours and take meas - ures to eliminate the consequences within the cor - rection period. During the investigation conducted by the working mechanism, foreign entities may make statements and defend themselves. If a foreign entity is restricted or prohibited from engaging in import and export activities related to China, and Chinese enterprises, other organisations or individuals need to conduct transactions with the foreign entity under special circumstances, they can apply to the Office of the Working Mechanism, and with its consent, they can conduct corresponding transactions with the foreign entities. 4.2 Remedies The working mechanism under the Provisions on the Unreliable Entity List can decide to suspend or termi - nate the investigation based on the actual situation; if there is a significant change in the facts on which the decision to suspend the investigation is based, the investigation may be resumed. The working mechanism may decide to remove the relevant foreign entities from the list of unreliable enti - ties based on the actual situation. If a foreign entity corrects its behaviour and takes measures to eliminate the consequences of its behaviour within the specified correction period in the announcement, the working mechanism shall make a decision to remove it from the list of unreliable entities. Foreign entities can apply to be removed from the list of unreliable entities, and the working mechanism will decide whether to remove them based on the actual situation.

74 CHAMBERS.COM