Sanctions 2026

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

Relevant provisions on countermeasures If a foreign organisation or individual endangers Chi - na’s national sovereignty, security, or development interests; violates normal market transaction princi - ples by disrupting usual transactions with Chinese enterprises, other organisations, or individuals; or adopts discriminatory measures against investors and their overseas investments, unreasonably depriving or restricting investors and their legitimate rights and interests in overseas investments, the relevant depart - ments of the State Council may take measures such as: i) prohibiting or restricting their import and export activities related to China; ii) prohibiting or restrict - ing their investment in the country; iii) prohibiting or restricting organisations or individuals within China from engaging in related transactions or cooperation with them; iv) prohibiting or restricting the entry of rel - evant personnel, products, and means of transport; and v) cancelling or restricting the work, stay, or resi - dence qualifications of relevant personnel in China. These measures may apply to organisations actually controlled or invested in by foreign organisations or individuals in their establishment or operation. Special anti-money laundering preventive measures These measures were introduced by the People’s Bank of China, the Ministry of Foreign Affairs, the Min - istry of Public Security, the Ministry of State Security, the Ministry of Justice, the Ministry of Finance, the Ministry of Housing and Urban-Rural Development, and the State Administration for Market Regulation on 13 January 2026, to take effect on 16 February 2026. Legislative purpose The aim of the measures is to prevent money laun - dering, terrorist financing, and the financing of the proliferation of weapons of mass destruction, and to regulate special anti-money laundering preventative measures. Relevant provisions regarding sanctions Any entity or individual must, in accordance with the law, take special anti-money laundering preventative measures against the following entities:

• all terrorist organisations and personnel identified by the National Counter-Terrorism Leading Group and announced by its office; • all organisations and personnel involved in targeted financial sanctions as notified by the Ministry of Foreign Affairs of implementation of UN Security Council resolutions; and • all organisations and personnel identified by the People’s Bank of China or jointly with relevant national authorities as having significant money laundering risks and where failure to take measures may result in serious consequences. In summary, judging from China’s relevant legisla - tion on countermeasures and sanctions by 2026, the country is placing increased emphasis on legisla - tion related to countermeasures and sanctions, and attaches great importance to using countermeasures to safeguard its national sovereignty, security, and development interests, to protect the legitimate rights and interests of its citizens and organisations, and to uphold international order in accordance with inter - national law. China’s Sanctions and Countermeasures Enforcement Cases in 2026 Ministry of Commerce order No 1 of 2026 cancelling countermeasures against two EU financial institutions The Ministry of Commerce of the People’s Republic of China issued the above order on 24 April 2026. In accordance with the Anti-Foreign Sanctions Law of the People’s Republic of China and the Provisions on the Implementation of the Anti-Foreign Sanctions Law of the People’s Republic of China and, given that the EU announced on 23 April 2026 the lifting of sanctions against two Chinese financial institutions, China decided, effective 24 April 2026 (Beijing time), to cancel the relevant countermeasures imposed by Ministry of Commerce Order No 5 of 2025 on the two EU banks UAB Urbo Bankas and AB Mano Bankas and to withdraw them from the countermeasures list.

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