Sanctions 2025

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

1. Trends and Overview 1.1 Sanctions Market

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 Law of the People’s Repub - lic of China on Countering Foreign Sanctions, organi - sations and individuals in China must comply with the anti-sanction measures prescribed by the relevant departments 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, that is, foreign enterprises, organisa - tions 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 Law of the People’s Republic of China on Counter - ing Foreign Sanctions stipulates that China can take countermeasures against discriminatory restrictive measures imposed by foreign countries.

In 2024 and 2025, China promulgated and revised several pieces of sanctions-related legislation, includ - ing the Provisions for the Implementation of the Law of the People’s Republic of China on Countering Foreign Sanctions (effective on 23 March 2025), the Anti-Money Laundering Law of the People’s Republic of China (revised in 2024 and effective on 1 Janu - ary 2025), the Regulations of the People’s Republic of China on Export Control of Dual-Use Items (effec - tive on 1 December 2024), and the Dual-Use Export Control List of the People’s Republic of China, and adjusted the controlled items several times. At the same time, anti-sanctions law enforcement activities are also quite active. The Ministry of Foreign Affairs and the Ministry of Commerce have repeatedly taken countermeasures and punitive measures to restrict the relevant activities of foreign entities that endan - ger China’s national interests and undermine the legitimate rights and interests of Chinese companies and individuals. According to statistics, in 2024, the number of foreign companies, individuals and institu - tions included in the countermeasures list increased from seven in 2023 to 100, and the number of foreign companies, individuals and institutions included in the unreliable entity list increased from two in 2023 to four, and two were investigated. 1.2 Key Trends China has been continuously improving its anti-sanc - tion legislation and strengthening the implementa - tion of its anti-sanction system in law enforcement and judicial aspects. In the Report on the Work of the Supreme People’s Court of the People’s Republic of China, which came into effect on 8 March 2025, it was mentioned that the rule of law in foreign-related mat - ters should be strengthened and the effectiveness of foreign-related judicial affairs should be improved. The report also called for countering illegal sanctions and so-called long-arm jurisdiction in accordance with the law, with a firm commitment to safeguarding national sovereignty, security, and developmental interests. At the same time, China has been actively strengthening its export control system. This includes formulating and enforcing strict regulations to regulate the transfer of sensitive technologies and dual-use items.

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