China's Counter-Sanctions Framework Impacts Multinational Compliance
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- •China's counter-sanctions framework is now actively enforced, impacting multinationals.
- •Compliance with foreign sanctions may lead to breach of contract in China.
- •New decrees enhance China's power to respond to foreign measures and restrict investigations.
In 2026, China's counter-sanctions framework transitioned from theoretical to practical enforcement, affecting multinational companies. A Chinese court ruled that compliance with foreign sanctions does not protect against breach of contract, and new laws enhance Beijing's ability to respond to foreign measures. Recent actions include the issuance of Decree 835, which allows the Ministry of Justice to declare foreign laws as improper extraterritorial measures, making compliance unlawful for entities in China. This has implications for companies globally, as they must navigate conflicting regulations from different jurisdictions. The situation is evolving, with new regulatory updates and enforcement actions indicating a significant shift in China's legal landscape regarding foreign businesses.
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