China’s Counter-Sanctions Measures: An Up-to-Date Overview

On August 5, 2026, the Ministry of Commerce (“MOFCOM”), pursuant to the Anti-Foreign Sanctions Law, placed seven U.S. entities, including Applied DNA Sciences Inc., on the Countermeasure List, prohibiting any entities or individuals in China from engaging in transactions, cooperation, or other activities with them. This decision demonstrates that China is making increasingly active use of its counter-sanctions legal measures to respond to restrictive measures imposed by foreign countries against Chinese entities. For foreign companies conducting business with Chinese entities, a thorough grasp of China's counter-sanctions regime—and its attendant legal risks—is of growing strategic importance..