2025: A Review Of Foreign Sanctions And Export Control Developments Involving China

In early 2025, the United States introduced several new trade and outbound investment measures related to China. However, some of these measures were later adjusted or partially suspended following negotiations. During the same period, China expanded its export controls on rare earth materials, including extraterritorial rules, while it more frequently used its Export Control List ("ECL") and Unreliable Entity List ("UEL") to designate foreign entities.

FIGURE 1: CHINA LOOKBACK TIMELINE 2025

The following are some key takeaways from 2025:

• Expanded US restrictions on ICTS and outbound investment. The Securing the Information and Communications Technology and Services Supply Chain regulations (the "ICTS rule") under Executive Order 13873 took effect in February 2025, establishing a framework to review ICTS transactions involving critical infrastructure, sensitive personal data, and critical or emerging technologies. Relying on the same authority, the