Authored by: Huang Ling , Wang Xinghua (Owen) , Xu Jiaxing (Jason) , Liu Ning and Fang Wei
Against the backdrop of trade tensions with the United States during Donald Trump’s first presidential term, China began to develop its anti-sanctions legal framework. In 2020 and 2021, the Ministry of Commerce of the People’s Republic of China (“MOFCOM”) issued ministerial-level rules establishing the Unreliable Entity List and introducing mechanisms to counter the extraterritorial application of foreign sanctions and related restrictive measures.