China's Anti‑Foreign Sanctions Law Gets Teeth: Understanding The 2025 Implementation Regulations

April 14, 2025 – On March 23, China's State Council issued the Regulations on the Implementation of the Anti-Foreign Sanctions Law (Regulations), effective immediately. These Regulations clarify the 2021 Anti-Foreign Sanctions Law (AFSL) and expand China's legal tool kit to counter foreign sanctions it deems discriminatory or harmful to its sovereignty, security or development interests. Alongside this, China recently applied the AFSL in a legal proceeding for the first time, underscoring its readiness to deploy these measures to protect Chinese entities and individuals. Businesses and individuals with interests in China must be aware of these Regulations and understand their potential impact on operations, compliance obligations and exposure to countermeasures. This alert outlines the key developments and potential implications.