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.

In March 2025, Prime Minister Li Qiang signed Order of the State Council No. 803 Provisions for Implementing the Anti-Foreign Sanctions Law of the People’s Republic of China, which clarifies:

• that if a foreign country adopts “discriminatory restrictive measures” against Chinese citizens/entities, relevant government departments can include “relevant organisations, individuals, and organisations and individuals related to them” in a counter-measures list and to take countermeasures

• those targeted by countermeasures can apply to have them suspended/cancelled. Applicants should provide evidence of correcting their behaviour. Any changes to countermeasures may be subject to conditions

• “other types of property” that can be subject to seizure/detention/freezing under the Law include: cash, bills, bank deposits, securities, fund shares, equity, intellectual property rights, accounts receivable and other property and property rights

• “relevant transactions, cooperation, and other activities” that can be prohibited/restricted include activities in the fields of education, science and technology, legal services, environmental protection, economy and trade, culture, tourism, health and sports

• “other necessary measures” that can be implemented under the Law include (but are not limited to): prohibiting/restricting import and export activities related to China; prohibiting/restricting investment in China; prohibiting/restricting the provision of data/personal information to persons listed; cancelling/restricting work permits/stay/residence; and fines

• procedures for countermeasures (e.g. relevant department are authorised to conduct corresponding investigations and external consultations)

• government departments responsible for countermeasures will undertake work for countering foreign sanctions in line with their respective areas (e.g. commerce) but they shall coordinate and share information

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.