What Every Multinational Should Know About … China’s New Framework For Addressing Economic Sanctions And Supply Chain Risks

Recent Chinese government measures suggest that China is entering a new phase in the development of its counter-sanctions and anti-extraterritoriality framework. For several years, multinational companies have tracked China’s Anti-Foreign Sanctions Law, Blocking Rules, Unreliable Entity List regime, data laws, export control rules, and related measures as part of a growing — though only intermittently enforced — legal architecture. What now appears to be changing is not only the breadth of that framework but the extent to which Chinese authorities may be prepared to formalize and operationalize it in concrete commercial and regulatory settings.

Two new State Council decrees are central to that shift. State Council Decree No. 834 addresses industrial and supply-chain security and creates a broader framework for identifying, monitoring, and responding to risks affecting China’s industrial and supply chains. State Council Decree No. 835 establishes a more formal mechanism for