Sanctions 2026

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

China’s Sanctions Legislation in 2026 In 2026, China will see new developments in its sanc - tions legislation, as briefly summarised below. Regulations of the People’s Republic of China on countering improper extraterritorial jurisdiction by foreign states These regulations were promulgated by the State Council of the People’s Republic of China on 7 April 2026 and came into effect the same day, with applica - tion throughout the entire country. Legislative purpose The purpose of the regulations is to safeguard national sovereignty, security, and the development interests of the People’s Republic of China, to protect the legitimate rights and interests of Chinese citizens and organisations, and to uphold international order based on international law. Extraterritorial jurisdiction The regulations establish extraterritorial jurisdiction as well as a mechanism for negotiated settlement. In accordance with the laws of the People’s Republic of China and international treaties, the Chinese gov - ernment concluded or acceded to by the People’s Republic of China, or on the principle of reciprocity, has the right to implement extraterritorial jurisdiction measures against acts with appropriate connections to the country, in order to safeguard national sover - eignty, security, and development interests, and to protect the legitimate rights and interests of Chinese citizens and organisations. The Chinese government has jurisdiction over rel - evant acts in accordance with the preceding para - graph. If a foreign state claims jurisdiction over the same act, both parties may resolve the matter through treaty conclusion, diplomatic channels, or consulta - tion between competent authorities, based on mutual adherence to international law and the basic norms of international relations. Working objectives The Chinese state will establish and improve relevant working mechanisms for responding to undue foreign

extraterritorial jurisdiction and coordinate efforts to address such matters. Identification , assessment , and countermeasures and restrictive measures i) Identification The legal departments of the State Council of the People’s Republic of China, in conjunction with other relevant authorities, will conduct identification work on undue foreign extraterritorial jurisdiction measures, including investigations and consultations with foreign parties. The identification of undue foreign extrater - ritorial jurisdiction measures should comprehensively consider the following factors: • whether they violate international law and the basic norms of international relations; • whether the connection between measures subject to extraterritorial jurisdiction by the foreign state and that state is appropriate; • whether they endanger China’s national sovereign - ty, security, and development interests, or harm the legitimate rights and interests of Chinese citizens and organisations; and • consideration of other factors – if, upon identifica - tion, certain measures constitute improper extrater - ritorial jurisdiction by a foreign country, the State Council’s legal affairs department may issue a public announcement; no organisation or individual may execute or assist in the execution of improper extraterritorial jurisdiction measures by a foreign country. If a Chinese citizen or organisation, due to special circumstances, genuinely needs to execute or assist in the execution of improper extraterritorial jurisdic - tion measures by a foreign country, they should apply to the State Council’s legal affairs department and provide relevant facts and reasons, and the scope of execution or assistance, etc. Upon approval via the working mechanism and decision-making proce - dures, they may execute or assist in the execution of the relevant measures within a specific scope.

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