Sanctions 2025

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

Law Enforcement In 2024, China carried out 12 anti-sanction enforce - ment actions in accordance with the Law of the Peo - ple’s Republic of China on Countering Foreign Sanc - tions, and included 118 sanctioned targets (including 56 natural persons and 62 entities) in the counter - measures list. In the first two months of 2025, the Ministry of Commerce of the People’s Republic of China issued four consecutive announcements, list - ing 23 foreign entities in the Unreliable Entity List. On 2 January 2025, China included 28 US entities in the export control list. On 4 March 2025, the Ministry of Commerce issued a number of consecutive export control and countermeasure-related announcements, listing ten companies in the Unreliable Entity List and 15 US entities in the Export Control List. In addition, China also implements the UN Security Council resolutions on sanctions. Future Trends It is anticipated that China will continue to introduce more systems, regulations and rules that align with the Law of the People’s Republic of China on Countering Foreign Sanctions and the Export Control Law of the People’s Republic of China, further improve the rel - evant legislation on countering foreign sanctions and export controls, and ensure that various legal provi - sions are effectively implemented. At the law enforcement level, China will continue to safeguard the interests of the state, organisations and citizens through countermeasures and export controls in accordance with legal provisions. The courts will also conduct more relevant practices. Companies in China will also pay more attention to sanctions and China’s laws on countering foreign sanctions, estab - lish corresponding internal control and compliance systems, and effectively safeguard corporate interests and development.

departments of the State Council shall have the right to decide to include the above-mentioned entities and related organisations and individuals involved in litigation and judgment enforcement activities in the countermeasures list, and take countermeasures such as restricting entry, sealing, seizing or freezing property in China, prohibiting or restricting relevant transactions and co-operation with them, and reserve the right to carry out compulsory enforcement against property and other more severe countermeasures. No organisation or individual may execute or assist in the execution of the judgment resulting from the litiga - tion promoted or implemented by a foreign country, organisation or individual in the preceding paragraph. Revision of the Anti-Money Laundering Law of the People’s Republic of China Effective date The Anti-Money Laundering Law of the People’s Republic of China was revised and passed on 8 November 2024, and came into effect on 1 January 2025. Major amendments related to sanctions The revised law introduces several significant chang - es. It expands the scope to include the prevention and combating of terrorist financing activities. It also introduces the principle of universal jurisdiction, ena - bling China to take action against money laundering and terrorist financing activities conducted abroad if they are deemed to endanger China’s sovereignty and security, infringe upon the legitimate rights and interests of Chinese citizens, legal persons, or other organisations, or disrupt China’s financial order. The law also introduces special anti-money laundering preventive measures for entities and individuals des - ignated on specific sanctions-related lists. Addition - ally, it establishes an anti-money laundering monitor - ing agency with the aim of proactively managing and mitigating risks.

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