Auditing The Auditors

In Two Regulations, One Direction, we described the coordinated package China's State Council issued on April 7, 2026—Decree No. 834 on industrial and supply chain security and Decree No. 835 on countering "improper extraterritorial jurisdiction"—and observed that its significance would turn on how, and against whom, the new machinery was used. On August 5, Beijing answered part of that question. MOFCOM Order No. 2 of 2026 added six US entities to the countermeasure list maintained under the Anti-Foreign Sanctions Law (AFSL)¹ for "assisting and supporting" US Xinjiang-related sanctions, prohibiting organizations and individuals within China from any transactions or cooperation with them, effective immediately. Among the six is the Responsible Business Alliance (RBA)—the multi-stakeholder coalition whose Code of Conduct, Validated Assessment Program (VAP) audits, and Responsible Minerals Initiative (RMI) sit beneath a remarkable share of global supply chain due diligence. The