On 23 Mar. 2025, China’s State Council released the “Provisions on the Implementation of the Anti-Foreign Sanctions Law of the People’s Republic of China” (hereinafter the “Provisions”, 实施《中华人民共和国反外国制裁法》的规定), further refining the legal framework for countering foreign sanctions and enhancing its operability.
The Provisions specifies a wide range of countermeasures, including asset freezes (covering cash, equity, intellectual property, etc.), transaction restrictions (in areas such as trade, technology, and culture), as well as prohibitions on investment and cross-border data transfers. The Provisions also strengthens enforcement mechanisms by requiring coordinated efforts among relevant authorities and authorizing sanctions, such as restrictions on imports, exports, and data transfers, against entities that refuse to comply with countermeasures.
Notably, the Provisions extends the reach of countermeasures into the judicial arena. If a foreign country, organization, or individual harms China’s sovereignty, security, or development interests through lawsuits or other legal actions, the relevant parties may be placed on a countermeasure list.
This Provisions complements the 2021 Anti-Foreign Sanctions Law and aims to safeguard national interests in a complex international landscape.
Contributors: CJO Staff Contributors Team
