China — Sanctions & Embargoes

China operates a multi-layered restrictive-measures framework consisting of counter-sanctions statutes that respond to foreign restrictions on Chinese persons, export controls that gate dual-use and strategic items, and entity-list mechanisms that target foreign organizations and individuals. Understanding this architecture is essential for any company with cross-border exposure to China, whether as importer, exporter, or investor.

Anti-Foreign Sanctions Law (AFSL). Adopted by the Standing Committee of the National People's Congress on June 10, 2021, the Anti-Foreign Sanctions Law authorizes China's relevant departments to impose countermeasures against foreign entities and individuals that formulate, decide on, or implement discriminatory restrictive measures against Chinese citizens or organizations. The countermeasures enumerated in the statute include denial of visa or entry, deportation, asset freezes on movable and immovable property in China, and prohibitions on transactions, cooperation, or other activities with Chinese citizens and organizations. The Ministry of Foreign Affairs has applied the AFSL to impose countermeasures against foreign entities, including asset freezes and transaction prohibitions. Articles 3, 4, 5, 6, 9, and 15 of the AFSL specify the grounds for designation (endangering China's sovereignty, security, or development interests; participating in or assisting foreign discriminatory measures) and the available countermeasures (freezing property, prohibiting transactions and cooperation).

The State Council issued an implementing regulation on March 24, 2025, comprising 22 articles. This regulation specifies that countermeasures include the seizure, detention, and freezing of "other types of assets," and the prohibition or restriction of "relevant transactions, cooperation and other activities" as well as "other necessary measures" stipulated in the AFSL. The regulation further refines countermeasure procedures and strengthens coordination among State Council departments. Enforcement provisions authorize relevant departments to mandate corrections if countermeasures are not implemented in accordance with the law, and to prohibit or restrict certain activities of the involved parties.

Unreliable Entity List (UEL). Promulgated by the Ministry of Commerce (MOFCOM) on September 19, 2020 (MOFCOM Order No. 4 of 2020), the Provisions on the Unreliable Entity List authorize a MOFCOM-led working mechanism to add foreign entities that (1) endanger China's national sovereignty, security, or development interests, or (2) suspend normal transactions with Chinese companies or apply discriminatory measures in violation of normal market-trading principles and cause serious damage to the legitimate rights and interests of Chinese enterprises, other organizations, or individuals. Article 2 of the UEL Provisions sets out these two grounds. Article 10 permits the working mechanism to take one or more of the following measures: restricting or prohibiting the foreign entity from engaging in China-related import or export activities; restricting or prohibiting investment in China; restricting or prohibiting the entity's relevant personnel or means of transportation from entering China; restricting or revoking work permits, stay status, or residence in China; and imposing a fine of a corresponding amount according to the severity of the circumstances.

MOFCOM has invoked the UEL against foreign companies engaged in activities MOFCOM deemed harmful to China's interests. For example, in May 2024 MOFCOM added Boeing Defense, Space and Security, General Atomics Aeronautical Systems, and General Dynamics Land Systems to the UEL on the basis that these entities "repeatedly sold missiles, military drones, tanks and other offensive weapons to Taiwan," thereby "seriously undermining China's national security, sovereignty and territorial integrity" in violation of the One-China principle. MOFCOM spokesperson remarks consistently emphasize that the UEL "targets only a handful of foreign entities that threaten China's national security" and that "foreign entities that are honest and law-abiding have nothing to worry about."

Export Control Law (ECL). Adopted on October 17, 2020 and effective December 1, 2020, the Export Control Law establishes a unified legal framework for Chinese export controls on dual-use items (items with both civilian and military applications), military products, nuclear materials, certain chemicals, biological agents, and other items related to national security, international obligations, and foreign-policy considerations. The ECL sets out a control-list system, a licensing regime, and end-user / end-use certification requirements. The State Council and the Central Military Commission jointly administer export controls through their respective departments; the Ministry of Commerce administers dual-use export controls jointly with other agencies (the State Administration of Science, Technology and Industry for National Defense; the General Administration of Customs; the China Atomic Energy Authority; and other relevant ministries depending on item category).

Article 44 of the ECL provides that China may take reciprocal export-control measures against any country or region that "abuses export control measures and poses a threat to China's national security and interests." This extraterritorial countermeasures provision parallels the AFSL. The ECL also authorizes temporary controls (Article 11) and establishes a "control list" and a "restricted name list" (Article 23) to flag end users and end uses that present proliferation or national-security risks. Penalties for violations include confiscation of illegal proceeds, fines ranging from the amount of the illegal turnover to five times that amount, and, in serious cases, suspension or revocation of export licenses and criminal prosecution.

Administering agencies. The Ministry of Foreign Affairs (MOFACOM) determines and announces AFSL countermeasures. The Ministry of Commerce (MOFCOM) leads the Unreliable Entity List working mechanism and administers most dual-use export controls under the ECL. The General Administration of Customs (GACC) enforces export and import restrictions at the border. Sanctions and export-restriction decisions typically appear as MOFACOM or MOFCOM spokesperson statements, State Council regulations, or joint ministry announcements rather than as consolidated sanctions lists in the style of OFAC's Specially Designated Nationals (SDN) List.

Interaction with other Chinese trade laws. The Foreign Trade Law (2004, amended 2022) provides the statutory foundation for export and import restrictions and for trade remedies. Articles 16, 29, 30, and 31 authorize the State Council to restrict or prohibit imports and exports to safeguard national security, public interest, or compliance with international obligations, or in response to other countries' discriminatory trade measures. The National Security Law (2015) and the Data Security Law (2021) authorize restrictions on cross-border data transfers and technology exports when national-security concerns arise. All three regimes—AFSL countermeasures, the Unreliable Entity List, and ECL licensing—rest on this broader statutory scaffolding.

Source: Law of the People's Republic of China on Countering Foreign Sanctions (adopted June 10, 2021) Source: Regulation on Implementing the Anti-Foreign Sanctions Law (State Council, effective March 24, 2025) Source: Provisions on the Unreliable Entity List (MOFCOM Order No. 4 of 2020, September 19, 2020) Source: Export Control Law of the People's Republic of China (effective December 1, 2020) Source: MOFCOM Regular Press Conference (May 23, 2024) – Unreliable Entity List designation of Boeing Defense, General Atomics, General Dynamics

China's blocking statute — formally titled the Rules on Counteracting Unjustified Extra-territorial Application of Foreign Legislation and Other Measures (MOFCOM Order No. 1 of 2021, effective January 9, 2021) — creates a framework under which the Chinese government can prohibit Chinese persons from complying with foreign sanctions and export-control measures deemed to violate international law or unjustifiably restrict economic activity with third countries. The Rules authorize a State Council working mechanism led by MOFCOM to assess and designate foreign measures, issue prohibition orders, and enable Chinese persons to seek civil compensation from parties that comply with prohibited foreign measures. The blocking statute differs from the Anti-Foreign Sanctions Law (AFSL): while the AFSL imposes counter-sanctions on foreign persons (visa bans, asset freezes in China, transaction prohibitions with Chinese entities), the blocking statute prohibits compliance with targeted foreign measures and exposes complying parties to civil liability in Chinese courts.

Scope of application. Under Article 2 of the Rules, the blocking statute applies where extraterritorial application of foreign legislation or measures "in violation of international law and the basic principles of international relations, unjustifiably prohibits or restricts the citizens, legal persons or other organizations of China from engaging in normal economic, trade and related activities with a third State (or region) or its citizens, legal persons or other organizations." The statutory text targets secondary or extraterritorial sanctions — foreign measures that restrict a Chinese entity's transactions with a third country or third-country persons rather than with the sanctioning state itself. No foreign measures have been explicitly designated under the Rules in published prohibition orders as of May 2026, but the breadth of the statutory criteria (violation of international law, principles of sovereignty and non-interference, impact on Chinese sovereignty or interests) leaves substantial administrative discretion for the working mechanism. U.S. secondary sanctions targeting Iran, Cuba, and Russia, EU secondary sanctions, and U.S. export-control measures on deemed exports and the foreign direct product rule are widely understood as within the contemplated scope.

Reporting requirement. Article 5 requires a Chinese person who is "prohibited or restricted by foreign legislation and other measures from engaging in normal economic, trade and related activities with a third State (or region)" to "truthfully report such matters to the competent department of commerce of the State Council [MOFCOM] within 30 days." The Rules do not specify the event that triggers the 30-day clock — whether it is designation on a foreign sanctions list, receipt of a denied-party screening hit, notification by a foreign counterparty of a sanction-compliance issue, or entry into negotiations for a transaction that would violate a foreign measure. The reported matters must be kept confidential if the reporting party so requests. Failure to report truthfully exposes the Chinese person to a warning, a rectification order, and potential fines under Article 13.

Prohibition order process. Under Article 6, the working mechanism assesses whether the reported foreign measure constitutes "unjustified extra-territorial application" by considering: (1) whether international law or the basic principles of international relations are violated; (2) potential impact on China's national sovereignty, security, and development interests; (3) potential impact on the legitimate rights and interests of Chinese citizens, legal persons, or other organizations; and (4) "other factors that shall be taken into account." If the working mechanism determines the measure is unjustified, MOFCOM issues a prohibition order under Article 7. The prohibition order formally declares that Chinese persons shall not "recognize, execute, or comply with" the designated foreign measure. The working mechanism "may, based on actual circumstances, suspend or withdraw" a prohibition order, but the Rules do not specify the criteria for such suspension or withdrawal. No prohibition orders have been published on MOFCOM's website or in the China Foreign Trade and Economic Cooperation Gazette as of May 30, 2026.

Exemption mechanism. Article 8 permits a Chinese person to apply for exemption from compliance with a prohibition order. The application must be in writing, must state the reasons for the exemption and the scope of exemption sought, and is submitted to MOFCOM. MOFCOM has 30 days to decide whether to grant the exemption (decisions "shall be made in a timely manner in case of emergency"). The Rules do not enumerate the criteria for granting an exemption; MOFCOM has full discretion. An exemption shields the exempted party from civil liability under Article 9 for complying with the prohibited foreign measure. This mirrors the European Union Blocking Regulation (Council Regulation (EC) No 2271/96), which permits EU operators to apply for authorization to comply with listed U.S. extraterritorial measures on EU-Iran and EU-Cuba trade.

Civil liability for compliance. Article 9 establishes that "where a person complies with the foreign legislation and other measures within the scope of a prohibition order, and thus infringes upon the legitimate rights and interests of a citizen, legal person or other organization of China, the latter may, in accordance with law, institute legal proceedings in a people's court, and claim for compensation by the person; except where the former person is granted exemption in accordance with Article 8." The plaintiff may be any Chinese person (including Chinese subsidiaries of foreign multinationals) that suffers harm from the defendant's compliance with the prohibited foreign measure. The defendant can be a Chinese person, a foreign person, or a foreign multinational's China subsidiary that complied with the foreign sanction. The statute does not define "legitimate rights and interests" or specify a causation standard or measure of damages. Civil actions under Article 9 have not been publicly reported in Chinese court decisions or MOFCOM enforcement announcements as of May 30, 2026, likely because no prohibition order has been issued.

Government support for non-compliance. Article 11 provides that "where, in adherence to the prohibition order, a citizen, legal person or other organization of China suffers significant losses resulting from non-compliance with the relevant foreign legislation and other measures, relevant government departments may provide necessary support based on specific circumstances." This contemplates that a Chinese entity honoring a prohibition order — and thereby violating a U.S. or EU sanction — may face penalties (asset freezes, fines, loss of export privileges, criminal prosecution) in the foreign jurisdiction or loss of business with foreign counterparties. The "necessary support" is not defined and no public guidance clarifies whether it includes financial compensation, legal defense assistance, access to alternative markets, or diplomatic intervention. Article 10 separately provides that the working mechanism shall provide "guidance and service" to Chinese persons facing issues from foreign measures, but again does not specify the content.

Enforcement against Chinese persons. Article 13 permits MOFCOM to issue a warning, order rectification within a specified period, and "concurrently impose a fine according to the severity of the circumstances" on a Chinese person who fails to report truthfully under Article 5 or fails to comply with a prohibition order under Article 7. No fines or penalties under Article 13 have been publicly announced as of May 30, 2026. The absence of prohibition orders likely explains the absence of enforcement actions.

Exclusion for treaty obligations. Article 14 excludes from the Rules' scope "extraterritorial application of foreign legislation or other measures provided for in treaties or international agreements to which China is a party." This carve-out preserves China's obligations under the United Nations Security Council Chapter VII sanctions resolutions (e.g., North Korea UNSCR 1718 sanctions regime, Iran UNSCR 2231), the New York Convention on the Recognition and Enforcement of Foreign Arbitral Awards, and bilateral mutual legal-assistance treaties.

Operational risk. Multinational companies with China operations face a three-corner compliance dilemma when the blocking statute intersects with U.S. or EU secondary sanctions. Complying with a U.S. Office of Foreign Assets Control (OFAC) prohibition on transactions with a designated person may, if that transaction involves a Chinese entity transacting with a third-country person, trigger reporting obligations under Article 5, civil liability under Article 9 if MOFCOM issues a prohibition order, and penalties under Article 13. Conversely, adhering to a hypothetical MOFCOM prohibition order exposes the company to U.S. or EU sanctions penalties. The exemption mechanism under Article 8 provides a potential off-ramp but requires case-by-case MOFCOM approval with no published criteria. China subsidiaries of U.S. and EU multinationals are "Chinese persons" under PRC law and therefore subject to the blocking statute's reporting, prohibition, and penalty provisions, yet their foreign parents remain subject to U.S. and EU jurisdiction.

Source: Rules on Counteracting Unjustified Extra-territorial Application of Foreign Legislation and Other Measures (MOFCOM Order No. 1 of 2021, effective January 9, 2021)

China applies export licensing requirements to critical minerals essential for semiconductors, electric vehicles, defense systems, and renewable energy. The controls — administered by the Ministry of Commerce (MOFCOM) and the General Administration of Customs (GACC) — are widely understood as economic-statecraft responses to foreign semiconductor export controls targeting China. The licensing regime for gallium, germanium, and rare earths is the most operationally significant application of China's Export Control Law for foreign importers because China dominates global production of these minerals and because the licensing process gates access to materials with no near-term alternative suppliers at comparable scale or cost.

Gallium and germanium controls (effective August 1, 2023). On July 3, 2023, MOFCOM and GACC jointly announced export controls on gallium and germanium items, effective August 1, 2023. In a MOFCOM regular press conference on July 6, 2023, spokesperson Shu Jueting stated that "gallium and germanium-related items can be used for both military and civilian purposes" and that "export control on gallium and germanium-related items is international customary practice." Shu explained that the controls aim to "safeguard national security and better fulfill international obligations" by ensuring the items "are used for legitimate purposes." Shu clarified in response to a Bloomberg question that "export control is not about restricting amount or banning export" and that "China will review the applications for the export of items related to gallium and germanium in accordance with the law. Those that meet the requirements will be approved."

The July 3 announcement was made under the authority of China's Export Control Law, Foreign Trade Law, and Customs Law. The controlled items are specified by Harmonized System (HS) customs codes in the announcement; gallium is critical for semiconductors used in electric vehicles, 5G infrastructure, and defense applications, while germanium is essential for fiber optics, infrared systems, and certain photovoltaic cells. The MOFCOM announcement stated that the export control measures would be "implemented on August 1" and that MOFCOM had "not yet received any export applications from the businesses" as of July 6. MOFCOM confirmed that "once we receive such applications, we will review them in accordance with applicable laws and regulations."

Licensing approvals began in late 2023. In a November 30, 2023 MOFCOM press conference, a spokesperson confirmed that "since the implementation of these control measures from August 1, MOFCOM has received applications from enterprises for the exportation of gallium and germanium related items. We have approved after review some of the export applications, and some companies have obtained export licenses for dual-use items. MOFCOM will continue to review the applications and decide whether to grant approval." The press conference did not disclose the number of applications received, the number approved, the names of applicants or approved exporters, or the criteria applied in the review. The statutory basis for the licensing procedure is the Export Control Law (effective December 1, 2020) and the Measures for the Administration of Export Licenses for Dual-Use Items and Technologies (MOFCOM Order No. 29 of 2005, as amended). The end-use and end-user certification requirements described in the Export Control Law (Articles 12, 13, and 27) apply: exporters must provide information on the importer, end user, and end use, and the end user must undertake not to change the end use without MOFCOM approval.

Graphite controls (announced October 20, 2023, effective December 1, 2023). MOFCOM announced export licensing requirements for natural graphite items in October 2023, to take effect December 1, 2023. In the November 30, 2023 press conference, a reporter from Kyodo News noted that "China export control on graphite will come into force tomorrow. Graphite is a material used in EV batteries. The control measures will have an impact on the battery supply chain worldwide." MOFCOM did not provide further detail on the graphite licensing regime in the November press conference. Graphite is a critical input for lithium-ion battery anodes; China is the world's largest producer and processor of natural and spherical graphite.

Export ban on gallium, germanium, antimony, and superhard materials to the United States (December 3, 2024). On December 3, 2024, MOFCOM announced an outright ban on exports of gallium, germanium, antimony, and superhard materials to the United States, effective immediately. The announcement followed the U.S. Department of Commerce Bureau of Industry and Security's December 2, 2024 addition of Chinese entities to the Entity List. In a December 5, 2024 MOFCOM press conference, spokesperson He Yadong responded to a South China Morning Post question on U.S. condemnation of "China's new restrictions on exports of dual-use items and critical raw materials including gallium, germanium and graphite." He stated: "The U.S. has conducted such typical economic coercive acts as overstretching the concept of national security, abusing export control measures and taking unilateral, bullying measures against Chinese companies, undermining the international economic and trade order and disrupting the stability of global industrial and supply chains." The December 3 ban converts the August 2023 licensing regime into a destination-based prohibition for U.S.-bound gallium and germanium shipments.

Rare-earth export controls (February 18, 2025 and ongoing). On February 18, 2025, MOFCOM and GACC issued Announcement No. 18 of 2025, implementing export controls on medium and heavy rare-earth elements. The announcement states: "According to the relevant provisions of the Export Control Law of the People's Republic of China, the Foreign Trade Law of the People's Republic of China, the Customs Law of the People's Republic of China and the Regulations on Export Control of Dual-Use Items of the People's Republic of China, in order to safeguard national security and interests and fulfill international obligations such as non-proliferation, with the approval of the State Council, a decision is made to implement export control on the following items: I. Samarium related items [followed by detailed specifications]." The announcement lists seven rare-earth elements (samarium, europium, gadolinium, terbium, dysprosium, holmium, and lutetium) plus derivatives and alloys, each identified by HS code and technical specification (purity thresholds, compound formulas, and product forms). These rare earths are essential for high-strength permanent magnets in electric-vehicle motors, wind turbines, guided missiles, jet engines, and precision optics. China is the dominant global producer of rare-earth oxides, metals, and magnets. The announcement does not specify an effective date or transition period; under Article 11 of the Export Control Law, MOFCOM may impose temporary controls immediately upon announcement. A December 18, 2025 MOFCOM press conference noted that "since the implementation of export controls on rare earth-related items, Chinese authorities have conducted policy briefings for enterprises," but provided no additional procedural or statistical detail.

Operational risk for foreign importers. Importers of Chinese gallium, germanium, graphite, and rare earths must navigate a licensing process whose approval criteria, review timelines, and denial rates are not publicly disclosed. MOFCOM's July 2023 and November 2023 statements confirm that applications are reviewed "in accordance with applicable laws and regulations" and that compliant applications will be approved, but MOFCOM has not published licensing statistics, approval rates, or case examples. The December 2024 U.S. export ban eliminates the licensing pathway for U.S. persons and entities entirely. For non-U.S. importers, the end-use and end-user certification requirements create compliance risk: the foreign buyer must disclose the ultimate consignee and intended application, and any subsequent change in end use or end user without MOFCOM approval may trigger designation on MOFCOM's control list of importers and end users, resulting in suspension or prohibition of future exports. Companies in semiconductor, defense, electric-vehicle, and renewable-energy supply chains should assess sourcing alternatives and evaluate inventory buffers to manage licensing delays and potential denials, particularly for end uses or end users that may be deemed sensitive by MOFCOM (e.g., defense contractors, companies subject to U.S. or allied export controls on China, or firms flagged for geopolitical reasons).

Source: MOFCOM Regular Press Conference (July 6, 2023) — gallium and germanium controls Source: MOFCOM Regular Press Conference (November 30, 2023) — licensing approvals and graphite controls Source: MOFCOM Regular Press Conference (December 5, 2024) — U.S. export ban Source: MOFCOM and GACC Announcement No. 18 of 2025 — rare-earth export controls (February 18, 2025)

China's Ministry of Commerce (MOFCOM) has designated foreign entities on the Unreliable Entity List (UEL) since February 2023, imposing transaction prohibitions, investment restrictions, visa bans, fines, and asset freezes. The UEL is China's primary mechanism for publicly designating foreign companies and persons deemed to endanger China's national sovereignty, security, or development interests or to suspend normal transactions with Chinese entities in violation of market principles. Designations through mid-2025 overwhelmingly target U.S. defense contractors involved in arms sales to Taiwan, though MOFCOM has also designated companies for non-defense activities including supply-chain decisions related to Xinjiang. MOFCOM has not published a consolidated, machine-readable UEL; practitioners must compile designations from individual MOFCOM announcements and spokesperson remarks.

First designations (February 16, 2023). MOFCOM announced the first-ever UEL designations on February 16, 2023, adding Lockheed Martin Corporation and Raytheon Missiles & Defense on the basis of repeated arms sales to Taiwan. The designation decision imposed the following measures: (1) prohibition of any import and export business involving China; (2) prohibition of any new investment in China; (3) prohibition of entry into China by senior management of the two entities; (4) revocation of work permits, stay status, and residence permits of senior management in China; and (5) a fine levied against each entity. MOFCOM did not publish the fine amounts. The February 2023 designations marked the first use of the UEL since the Provisions on the Unreliable Entity List (MOFCOM Order No. 4 of 2020) entered into force on September 19, 2020.

May 2024 designations — Boeing Defense, General Atomics, General Dynamics. On May 20, 2024, MOFCOM added Boeing Defense, Space & Security, General Atomics Aeronautical Systems, and General Dynamics Land Systems to the UEL for repeatedly selling missiles, military drones, tanks, and other offensive weapons to Taiwan in violation of the One-China principle. The measures were identical to the February 2023 sanctions: prohibition of import/export activities with China, prohibition of new investment in China, prohibition of senior management entry into China, and revocation of senior management work permits and residence permits in China. MOFCOM levied a fine on Boeing Defense, Space & Security equal to double the amount of its sales contracts with Taiwan since the implementation of the UEL (i.e., since September 19, 2020), payable within 15 days of the announcement or face additional fines. The announcement did not specify the contract value or the calculated fine amount. In a May 23, 2024 MOFCOM regular press conference, a spokesperson stated that "China repeatedly and firmly opposed the US arms sales to China's Taiwan region" and that the three designated entities "have over the years repeatedly sold missiles, military drones, tanks and other offensive weapons to Taiwan, seriously undermining China's national security, sovereignty and territorial integrity, and violating the one-China principle."

The May 2024 announcement also warned Caplugs Corporation (USA) — an American company specializing in product protection — that there was evidence it had circumvented the UEL Provisions by transferring goods purchased from China to entities on the UEL. MOFCOM required Caplugs to cease such actions immediately and submit evidence to the UEL working mechanism office, or face additional legal measures. This is the first public indication that MOFCOM intends to enforce secondary sanctions or accessory liability against entities facilitating transactions with UEL-designated persons.

October 2025 designations — Saronic, Aerkomm, Oceaneering, Dedrone, TechInsights, Elbit Systems. On October 10, 2025, MOFCOM added Saronic Technologies, Inc., Aerkomm Inc., and Oceaneering International, Inc. to the UEL for engaging in military-technical cooperation with Taiwan despite China's firm opposition. In a spokesperson's remark published October 10, 2025, MOFCOM stated that the three firms' actions "seriously undermined China's national sovereignty, security, and development interests" and that the designation was made "pursuant to Article 2 of the Provisions on the Unreliable Entity List, as well as the Foreign Trade Law, the National Security Law, and the Anti-Foreign Sanctions Law of the People's Republic of China." The measures took effect immediately and prohibited the entities from engaging in import or export activities related to China and barred new investments in China.

On October 16, 2025, in a MOFCOM spokesperson's remark addressing the addition of Dedrone by Axon, TechInsights Inc. and its branches, and other foreign entities to the UEL, MOFCOM stated that these entities had "engaged in so-called military-technical cooperation with China's Taiwan region, made egregious statements concerning China, and assisted foreign governments in suppressing Chinese enterprises," thereby "seriously undermining China's national sovereignty, security, and development interests." The designation was made "pursuant to Article 2 of the Provisions on the Unreliable Entity List, as well as the Foreign Trade Law, the National Security Law, and the Anti-Foreign Sanctions Law." The measures took effect immediately. The October 16 announcement did not enumerate all designated entities by name or specify the full list of measures beyond the statutory authorities invoked.

Restricted Name List (export-control end-user list) vs. UEL. China also maintains a Restricted Name List under the Export Control Law, distinct from the UEL. The Restricted Name List is an end-user and end-use control list that prohibits exports of dual-use items to listed entities. On October 10, 2025, MOFCOM announced the addition of three U.S. entities to the Restricted Name List for endangering China's national security and interests, stating: "To safeguard national security and interests, perform non-proliferation and other international obligations, in accordance with relevant provisions of the Export Control Law of the People's Republic of China and the Regulations on Export Control of Dual-Use Items of the People's Republic of China, China has decided to add three U.S. entities that endanger China's national security and interests to the Restricted Name List. It is strictly prohibited to export dual-use items to these entities, and no exporter shall violate the aforementioned provisions." The announcement did not identify the three U.S. entities by name. The Restricted Name List is administered under the Export Control Law and the Regulations on Export Control of Dual-Use Items, rather than the UEL Provisions. Foreign companies should distinguish the two lists: UEL designations impose transaction prohibitions, investment bans, visa restrictions, and fines on the designated entity itself, while Restricted Name List designations prohibit Chinese exporters from shipping dual-use items to the listed end user without a license.

Operational risk. Foreign entities on the UEL face prohibition of imports from and exports to China, prohibition of new investment in China, prohibition of senior-management entry and revocation of work permits and residence permits, and financial penalties. Chinese entities — including Chinese subsidiaries of foreign multinationals — are prohibited from transacting with UEL-designated persons. The May 2024 Caplugs warning suggests that MOFCOM may impose secondary sanctions or accessory liability on entities that facilitate transactions with UEL-designated persons or transfer Chinese-origin goods or technology to them. Companies with China operations, Chinese supply chains, or Chinese customers should screen counterparties against the UEL and maintain documentation of end-use and end-user certifications, particularly for dual-use items and technology. MOFCOM has not published a consolidated UEL in machine-readable or searchable format as of October 2025; practitioners must compile designations from individual MOFCOM announcements, spokesperson remarks, and press conferences. Trade-press sources and law-firm summaries report additional UEL designations in late 2024, early 2025, and late 2025, including designations of PVH Group, Illumina, and additional defense contractors, but these reports cannot be confirmed from MOFCOM official English-language announcements as of June 1, 2026.

Unable to confirm as of 2026-06-01.

Source: MOFCOM Regular Press Conference (May 23, 2024) — UEL designation of Boeing Defense, General Atomics, General Dynamics Source: MOFCOM Spokesperson's Remarks on Adding Three U.S. Companies to the Unreliable Entity List (October 10, 2025) — Saronic Technologies, Aerkomm, Oceaneering Source: MOFCOM Spokesperson's Remarks on Measures Concerning the Unreliable Entity List (October 16, 2025) — Dedrone, TechInsights, Elbit Systems Source: MOFCOM Spokesperson's Remarks on the Addition of Three U.S. Entities to the Restricted Name List (October 10, 2025)

The Ministry of Foreign Affairs (MFA) imposes countermeasures against foreign individuals and entities under the Anti-Foreign Sanctions Law (AFSL) through ministerial decrees that take immediate effect. Each decree freezes assets in China, prohibits transactions with Chinese persons, and denies entry visas. Unlike the Ministry of Commerce's Unreliable Entity List (UEL), which targets entities that suspend normal transactions with Chinese companies or endanger China's national interests, the MFA countermeasures list focuses on foreign persons who formulate, decide on, or implement discriminatory restrictive measures against Chinese citizens or organizations or who participate in activities deemed to interfere in China's internal affairs — particularly arms sales to Taiwan. As of June 2026, the MFA has issued at least 19 numbered decrees designating over 100 individuals and entities under the AFSL since the law entered into force in June 2021. The countermeasures regime is administered by the MFA pursuant to Articles 3, 4, 5, 6, 9, and 15 of the AFSL and the March 2025 Regulations on Implementation of the Anti-Foreign Sanctions Law.

Statutory basis and countermeasures imposed. Under Article 3 of the AFSL, China may take countermeasures where a foreign country "violates international law and basic norms governing international relations, uses various pretexts or its own laws to contain and suppress China, adopts discriminatory or restrictive measures against Chinese citizens and organizations, and interferes in China's internal affairs." Article 5 enumerates the countermeasures: (1) denial of visa or deportation; (2) seizure, detention, or freezing of movable property, immovable property, and other assets within China; (3) prohibition or restriction on organizations and individuals within China from engaging in transactions, cooperation, or other activities with the designated person; and (4) other necessary measures. The March 2025 implementation regulations clarify that "other assets" includes cash, negotiable instruments, bank deposits, securities, fund shares, equity, intellectual property, accounts receivable, and other property and property rights. Article 6 of the AFSL permits the MFA or other relevant State Council departments to designate not only the primary person but also the spouse and immediate family members of designated individuals, senior management personnel of designated organizations, and organizations controlled or actually managed by designated persons.

Pattern of designations: focus on arms sales to Taiwan. The overwhelming majority of MFA countermeasures decrees since 2024 respond to U.S. arms sales to Taiwan. On April 11, 2024, the MFA issued Decree No. 5, freezing assets and prohibiting transactions with General Atomics Aeronautical Systems and General Dynamics Land Systems (two companies involved in repeated arms sales to Taiwan) and denying their senior personnel entry into China. On June 21, 2024, Decree No. 8 sanctioned three Lockheed Martin entities — Lockheed Martin Missile System Integration Lab, Lockheed Martin Advanced Technology Laboratories, and Lockheed Martin Ventures — plus three senior executives: James Donald Taiclet (Chairman, President, and Chief Executive Officer), Frank Andrew St. John (Chief Operating Officer), and Jesus Malave (Chief Financial Officer). The decree froze all movable and immovable property and other assets of the three entities and three individuals within China, prohibited all organizations and individuals in China from engaging in transactions, cooperation, or other activities with them, and denied the three executives visas or entry into China (including Hong Kong and Macao).

On September 18, 2024, Decree No. 12 sanctioned nine U.S. military contractors following another U.S. arms sale to Taiwan: Sierra Nevada Corporation, Stick Rudder Enterprises LLC, Cubic Corporation, S3 AeroDefense, TCOM, Limited Partnership, TextOre, Planate Management Group, ACT1 Federal, and Exovera. The decree froze assets, prohibited transactions, and denied entry to senior personnel of these firms. On December 27, 2024, Decree No. 16 responded to U.S. military assistance and the National Defense Authorization Act for Fiscal Year 2025 by sanctioning seven companies: Insitu, Inc., Hudson Technologies Co., Saronic Technologies, Inc., Raytheon Canada, Raytheon Australia, and Aerkomm Inc. (the seventh entity was not fully named in the available excerpt).

On December 26, 2025, Decree No. 19 designated 20 U.S. military-related companies and 10 senior executives following large-scale arms sales to Taiwan. The 20 companies include Northrop Grumman Systems Corporation, L3Harris Maritime Services, Boeing in St. [Louis] (partial name available), and others. The 10 executives include Palmer Luckey (founder of Anduril Industries), John Cantillon (Vice President of L3Harris Technologies and L3Harris Maritime Services), Michael J. Carnovale (President and CEO of Advanced Acoustic Concepts), John A. Cuomo (President and CEO of VSE Corporation), Mitch McDonald (President of Teal Drones, Inc.), Anshuman Roy (founder and CEO of Rhombus Power Inc.), Dan Smoot (President and CEO of Vantor), Aaditya Devarakonda (CEO of Dedrone Holdings Inc.), and Ann Wood (President of High Point Aerotechnologies). Each decree specifies that movable and immovable properties and other assets within China shall be frozen, all organizations and individuals within China shall be prohibited from engaging in transactions, cooperation, or other activities with the designated persons, and the individuals shall be denied visas or entry into China.

Designation procedures and publication. The MFA issues countermeasures through numbered ministerial decrees. Each decree states the statutory basis (Articles 3, 4, 5, 6, 9, and 15 of the AFSL), the grounds for the countermeasure (typically "seriously violates the one-China principle and the three China-U.S. Joint Communiqués, interferes in China's internal affairs, and undermines China's sovereignty and territorial integrity"), and the effective date (the date of issuance; countermeasures take effect immediately). The decrees are published on the MFA website in Chinese and English. There is no advance notice, no pre-designation investigation process disclosed to the designated person, and no hearing or administrative appeal procedure before designation. The March 2025 implementation regulations introduce a petition mechanism under which a designated person may apply to the relevant State Council department (the MFA for countermeasures under the AFSL) to suspend, modify, or cancel the countermeasure. The regulations do not specify the criteria for granting such relief. As of July 2025, only one entity — Viasat — has been removed from the countermeasures list; Viasat was designated on January 7, 2024 and removed on July 22, 2024 "due to the change in the circumstances on which the sanction is based," according to trade-press reports citing MFA announcements.

No consolidated public list. The MFA does not publish a consolidated, machine-readable countermeasures list comparable to the U.S. Office of Foreign Assets Control (OFAC) Specially Designated Nationals (SDN) List. Practitioners must compile designations from individual MFA decrees, spokesperson remarks, and press releases. The MFA website includes a dedicated page for countermeasures announcements under the category "Decision on Taking Countermeasures," but the page is not a filterable database. Trade-press sources report that, as of July 2025, the MFA had carried out 11 countermeasure enforcement actions comprising 56 individuals and 57 entities, but a complete verified list is not publicly available in a single primary-source document. Some decrees list only partial entity names or refer to entities "as listed in the attached List of Targets of Countermeasures" without reproducing the full list in the published text.

Extraterritorial scope and secondary liability. Article 6 of the AFSL authorizes the MFA to designate not only the person who directly participated in the discriminatory foreign measure but also the spouse and immediate family members of a designated individual, senior management of a designated organization, and organizations controlled or actually managed by designated persons. This permits secondary sanctions-style liability. The 2025 implementation regulations further clarify that asset freezes apply to "cash, negotiable instruments, bank deposits, securities, fund shares, equity, intellectual property, accounts receivable, and other property and property rights," significantly expanding the range of frozen assets beyond physical real estate and bank accounts. Chinese subsidiaries of foreign multinationals are subject to the prohibition on transactions with designated persons even if the parent company is not itself designated. Violations by Chinese persons (failure to freeze assets or engaging in transactions with a designated person) may result in administrative penalties (warning, rectification order, fines, prohibition or restriction of related activities) or, in serious cases, criminal liability.

Operational risk. Foreign companies with operations in China, Chinese supply chains, or Chinese customers must screen counterparties against MFA countermeasures designations. The absence of a consolidated, machine-readable list increases compliance burden. Companies in the defense sector, aerospace, or other industries with Taiwan-related activities face the highest designation risk. The MFA has extended countermeasures to subsidiaries (Raytheon Canada, Raytheon Australia), individual executives (CEOs, CFOs, COOs, founders, presidents), and supporting entities (laboratories, venture-capital arms), demonstrating broad application. Once designated, a person's assets in China are frozen immediately, Chinese persons are prohibited from transacting with the designated person, and the individual is banned from entering China (including Hong Kong and Macao). The prohibition on transactions extends to Chinese subsidiaries of the designated entity's customers, suppliers, and business partners, creating supply-chain disruption risk. The petition mechanism introduced in the March 2025 regulations provides a theoretical off-ramp, but no public guidance clarifies the criteria for suspension or cancellation of countermeasures, and only one entity (Viasat) has been delisted as of mid-2025.

Source: Decision on Taking Countermeasures Against General Atomics Aeronautical Systems and General Dynamics Land Systems (MFA Decree No. 5, April 11, 2024) Source: Decision on Taking Countermeasures Against Entities and Senior Executives of Lockheed Martin Corporation (MFA Decree No. 8, June 21, 2024) Source: Decision on Taking Countermeasures Against U.S. Military Companies (MFA Decree No. 12, September 18, 2024) Source: Decision on Taking Countermeasures Against U.S. Military Companies and Senior Executives (MFA Decree No. 16, December 27, 2024) Source: Decision on Taking Countermeasures Against U.S. Military-Related Companies and Senior Executives (MFA Decree No. 19, December 26, 2025)