Sanctions 2025

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

trolled items without permission” – may also result in criminal liability. Under applicable legal provisions, such acts may constitute crimes such as “the crime of smuggling goods and articles prohibited from being imported and exported by the state” and “illegal busi - ness operations”, and may be punished accordingly. Recent Developments in China’s Sanctions Regime Provisions for the implementation of the Law of the People’s Republic of China on Countering Foreign Sanctions Effective Date The “Provisions for the Implementation of the Law of the People’s Republic of China on Countering Foreign Sanctions” were adopted at the State Council Stand - ing Committee meeting and came into effect on 23 March 2025. Departments implementing countermeasures The refusal to issue a visa, entry denial, visa cancel - lation or deportation, per Article 6, Paragraph 1 of the Law of the People’s Republic of China on Countering Foreign Sanctions, shall be implemented by the rel - evant departments of the State Council, such as the Ministry of Foreign Affairs and the National Immigra - tion Administration, in accordance with their duties and powers. The sealing, seizure and freezing, per Article 6, Para - graph 2 of the Law of the People’s Republic of China on Countering Foreign Sanctions, shall be implement - ed by the relevant departments of the State Council, such as the Ministry of Public Security, the Ministry of Finance, the Ministry of Natural Resources, the Min - istry of Transport, the Administration of Customs, the Administration of Market Regulation, the Administra - tion of Financial Management, and the Administration of Intellectual Property, in accordance with their duties and powers. The other types of property, per Article 6, Paragraph 2 of the Law of the People’s Republic of China on Countering Foreign Sanctions, include cash, bills, bank deposits, securities, fund shares, equity, intel - lectual property rights, accounts receivable and other property and property rights.

The prohibition or restriction of organisations and individuals within the territory of China from engag - ing in relevant transactions, co-operation and other activities with them, per Article 6, Paragraph 3 of the Law of the People’s Republic of China on Countering Foreign Sanctions, including but not limited to activi - ties in the fields of education, science and technology, legal services, environmental protection, economy and trade, culture, tourism, health and sports, shall be implemented by the relevant departments of the State Council, such as education, science and technology, judicial administration, ecological environment, com - merce, culture and tourism, health and sports admin - istration, in accordance with their duties and powers. Other necessary measures, per Article 6, Paragraph 4 of the Law of the People’s Republic of China on Countering Foreign Sanctions, include, but are not limited to, prohibiting or restricting import and export activities related to our country, prohibiting or restrict - ing investment in our country, prohibiting the export of relevant items to them, prohibiting or restricting the provision of data and personal information to them, cancelling or restricting the work permits, stay or resi - dency qualifications of their relevant personnel in our country, and imposing fines. Risk of being sued for enforcing or assisting in enforcing “foreign discriminatory restrictive” measures If any organisation or individual implements or assists in the implementation of measures, by foreign countries against Chinese citizens or organisations, deemed to be discriminatory, restrictive, and infring - ing upon the legitimate rights and interests of Chinese citizens or organisations, Chinese citizens and organi - sations have the right to file a lawsuit in the people’s court in accordance with the law, demanding that the infringement be stopped and compensation for the losses be paid. Risk of countermeasures against foreign countries, organisations or individuals that “endanger China’s sovereignty, security and development interests” If a foreign country, organisation or individual is deemed, by the Chinese state, to endanger China’s sovereignty, security or development interests by promoting or implementing litigation, the relevant

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