Sanctions 2025

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

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 Law of the People’s Republic of China on Countering Foreign Sanctions were passed and were implemented on 23 March 2025. 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. According to the Provisions on the List of Unreliable Entities, a correction deadline can be set for foreign entities included in the list of unreliable entities, dur - ing 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. 4. Delisting Challenges 4.1 Process

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 List of Unreliable Entities can decide to suspend or terminate the investigation based on the actual situ - ation; 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. 4.3 Timing The Provisions on the List of Unreliable Entities do not specify a time limit to obtain delisting. However, the decision to remove foreign entities from the list of unreliable entities should be announced. From the date of announcement, the sanctions measures taken in accordance with the Provisions on the List of Unreli - able Entities shall cease to be implemented. 5. Trade and Export Restrictions 5.1 Services China’s export and import control regimes are cur - rently not country-specific. The Ministry of Commerce regularly issues the Catalogue of Technologies Pro - hibited or Restricted from Exporting in China and the Catalogue of Technologies Prohibited or Restricted from Importing in China.

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