ARTICLE · 09 NOVEMBER 2026
Update On Counter Sanctions And Their Impact On Multinationals
As multinational corporations navigate an increasingly complex regulatory landscape, compliance decisions made at the group level are encountering heightened scrutiny and risk both within China's borders and across international jurisdictions. The convergence of stricter enforcement mechanisms, evolving regulatory frameworks, and geopolitical tensions is creating unprecedented challenges for organizations attempting to maintain consistent compliance standards across their global operations.
ChinaCorporate/Commercial Law
Why should I read this?
In June, our article set out the growing tension between China’s counter-sanctions framework and supply chain due diligence requirements, such as those introduced by EU authorities. Since then, Beijing has moved from building that framework to using it, while also introducing new laws.
New rules on foreign trade, outbound investment and exit and entry strengthen Beijing’s powers to respond to foreign measures, while a draft Anti-Cross-Border Corruption Law would restrict foreign investigations in China. Recent sanctions on US and EU businesses show these powers used in practice. Their reach is not confined to China: multinational groups, wherever headquartered, may need to consider how decisions taken elsewhere, such as on sanctions compliance or internal investigations, affect their Chinese subsidiaries, suppliers and employees. For multinationals, this adds to an already complex compliance environment, where different regulatory requirements can
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