CHINA Trends and Developments Contributed by: Xing Nan (Nancy), AnJie Broad Law Firm
Ministry of Commerce announcement No 21 of 2026 blocking the injunction against US sanctions on five Chinese companies involving Iranian oil transactions On 2 May 2026, the Ministry of Commerce of the Peo - ple’s Republic of China issued the above announce - ment. The injunction in question stated that, in accord - ance with the National Security Law of the People’s Republic of China, the Foreign Relations Law of the People’s Republic of China, the Anti-Foreign Sanc - tions Law of the People’s Republic of China and its implementing regulations, and the Measures for Blocking the Improper Extraterritorial Application of Foreign Laws and Measures, the working mechanism of the Blocking Measures had conducted a compre - hensive assessment of the US sanctions against Hengli Petrochemical (Dalian) Refining Co Ltd and other companies, including their inclusion on the ‘Specially Designated Nationals List’ (SDN List), asset freezes, and transaction bans, based on their partici - pation in Iranian oil transactions: “The assessment confirms that the US sanctions against these com - panies constitute improper extraterritorial applica - tion. To safeguard national sovereignty, security, and development interests, and to protect the legitimate rights and interests of Chinese citizens, legal persons, and other organisations, the Ministry of Commerce, in accordance with Articles 2, 4, 6, and 7 of the Blocking Measures and the decision of the working mechanism, hereby issues the following prohibition: China will not recognise, implement, or comply with the sanctions imposed by the US on Hengli Petrochemical (Dalian) Refining & Chemical Co, Ltd, Shandong Shouguang Luqing Petrochemical Co, Ltd, Shandong Jincheng Petrochemical Group Co, Ltd, Hebei Xinhai Chemi - cal Group Co, Ltd, and Shandong Shengxing Chemi - cal Co, Ltd, pursuant to Executive Orders 13902 and 13846, on the grounds of their participation in Iranian oil transactions, including inclusion on the ‘Specially Designated Nationals List’, asset freezes, and trans - action bans”.
Future Trends and Outlook We believe that, in the future, China will continue to introduce more systems, regulations, and rules to complement the Anti-Foreign Sanctions Law of the People’s Republic of China and the Export Control Law of the People’s Republic of China, further improv - ing relevant legislation on anti-foreign sanctions and export controls to ensure the effective implementation of various legal provisions. At the enforcement level, China will also continue to safeguard the interests of the Chinese state, organisations, and citizens through countermeasures and export controls in accordance with legal provisions. The courts will also conduct more related practices. Companies in China will pay closer attention to sanctions and Chinese laws regard - ing counter-sanctions, establishing corresponding internal control and compliance systems to effectively protect their interests and development.
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