China / PRC

China is a UN member state and implements UN sanctions.

In June 2021, China adopted the Anti-Foreign Sanctions Law 2021 (AFSL), which provides for the implementation of countermeasures against entities in foreign countries which have adopted “discriminatory and restrictive” measures against Chinese individuals or entities.

Article 6 outlines the countermeasures:

(1) “Refusal to issue visas, deny entry, visa cancellation or deportation;

(2) Sealing up, seizing, and freezing movable property, immovable property and other various types of property [in China];

(3) Prohibit or restrict relevant transactions, cooperation and other activities with organizations and individuals [in China]; and

(4) Other necessary measures.”

Article 12 authorises people and entities to sue for damages suffered as a result of compliance with foreign sanctions in Chinese domestic courts.

Separately to the AFSL, foreign entities may be added to China’s “Unreliable Entity List” which prohibits those entities from engaging in import/export activities related to China, prohibits them from making new investments in China, and subjects senior management figures to travel bans.

China has imposed travel bans on US Govt officials in response to the US’s designation of Chinese officials for human rights abuses, designated foreign ministers for visiting Taiwan, designated US defence companies for arms sales to Taiwan, and blocked imports from Lithuania in response to Lithuania opening a Taiwanese Representative Office in Vilnius.