Beijing, China — On March 23, 2025, China’s Prime Minister officially enacted the Implementation of the Anti-Foreign Sanctions Law, a significant measure aimed at countering unilateral sanctions imposed by foreign nations against China. This act provides a framework for identifying and restricting entities that the Chinese government deems to be retaliating against its interests.
According to the provisions of the new law, discriminatory measures targeting Chinese citizens or organizations can prompt the central authorities to designate corresponding entities, individuals, or organizations as part of countermeasures. The act is designed to provide the government with the ability to retaliate against foreign entities that threaten China’s sovereignty and security.
The law outlines that companies classified as endorsing or aiding actions harmful to China’s interests could be subject to penalties through the State Council’s relevant departments. Affected parties may apply to have these countermeasures suspended, provided they take corrective actions to alleviate the situations leading to their designation.
Those individuals or organizations listed under the act face a range of stringent consequences. The law details that designated persons could be denied entry to China, expelled, or have their assets confiscated or frozen. Additionally, there are restrictions on business engagements with local entities and limitations on the import and export of specific goods and technologies.
The act specifies that “other types of property” subject to seizure encompass cash, bank deposits, intellectual property rights, and other financial instruments. Furthermore, various sectors, including education, technology, legal services, and health, may face prohibitions on transactions and collaborative activities.
Another key element of the Implementation Act is the requirement for multiple government departments to coordinate in response to foreign sanctions and to share information pertinent to their areas of responsibility, such as commerce and trade.
This legislation signals China’s determination to establish a structured approach to counter sanctions that affect its entities and individuals. Given the unpredictable dynamics of global trade relations, experts recommend that companies with exposure to these regulatory risks—either through direct investment in China or through supply chain interactions—remain vigilant and informed about potential countermeasures.
The new law presents complex implications for international business and trade, highlighting the increasing interconnectedness of geopolitical actions and economic policies. As enterprises navigate this evolving landscape, awareness and due diligence will be essential to mitigate risks associated with sanctions and countermeasures.
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