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China's New Blocking Statute and Anti-Foreign Sanctions Law: Implications for Multinational Companies, Diligence, Reporting Obligations, and Impact on Affiliates

Recording of a 90-minute CLE video webinar with Q&A

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Conducted on Wednesday, July 14, 2021

Recorded event now available

or call 1-800-926-7926

This CLE course will guide counsel to multinational companies operating in China on China's new Blocking Statute and Anti-Foreign Sanctions Law. The panel will examine these new laws and their impact on multinational companies in China. The panel will address the obligations placed on multinational companies and their China-based affiliates and offer best practices for ensuring compliance.


In January 2021, China's Ministry of Commerce (MOFCOM) published The Rules on Counteracting Unjustified Extraterritorial Application of Foreign Legislation and Sanctions (the Blocking Statute), which was immediately effective. Similarly, the National People’s Congress passed the Anti-Foreign Sanctions Law on June 10, 2021. These laws are intended to counter the impact of foreign sanctions on Chinese persons.

Multinational companies that comply with sanctions against China or Chinese persons considered illegal under the Blocking Statute or the Anti-Sanction Law may face litigation. The Blocking Statute provides a legal basis and avenue to allow Chinese citizens and organizations to seek remedies resulting from economic and trade restrictions with persons and organizations of other countries. Similarly, Anti-Foreign Sanctions Law authorizes sanctions and counter-sanctions against individuals and organizations who, directly or indirectly, implement “discriminatory restrictive measures” against Chinese persons.

Companies subject to both foreign sanctions requirements and the new laws will likely face challenges in complying with both. Companies that have commercial contracts with Chinese entities should carefully review them to ensure compliance with the different applicable laws.

Listen as our authoritative panel of international trade attorneys examines China's new laws and related developments and the impact on multinational companies operating in China. The panel will address the obligations placed on multinational companies and their China-based affiliates. The panel will also discuss the need to review commercial contracts and new hurdles in diligence with Chinese entities to ensure compliance.



  1. China's new Blocking Statute and the Anti-Foreign Sanctions Law
    1. Reporting obligations
    2. Implicated foreign laws
    3. Exemption
    4. Private right of action
    5. Noncompliance
  2. Implications for multinational companies
    1. Obligations on multinationals
    2. Reporting obligations
    3. Diligence questions
    4. Potential liability and exposure to litigation
    5. Impact on affiliates
  3. Best practices
    1. Compliance
    2. Reviewing commercial contracts with Chinese entities


The panel will review these and other key issues:

  • What do China's new laws mean for multinational companies operating in China?
  • What steps should multinational companies in China take when facing inconsistent compliance obligations?
  • What penalties could result from noncompliance?


Cinelli, Giovanna
Giovanna M. Cinelli

Morgan, Lewis & Bockius

Ms. Cinelli is the leader of the firm’s international trade and national security practice. As a practitioner for...  |  Read More

Duffy, Melissa
Melissa Duffy


Ms. Duffy focuses her practice on a broad range of international trade matters, including export controls, OFAC...  |  Read More

Kostrzewa, Benjamin
Benjamin Kostrzewa

Foreign Legal Consultant
Hogan Lovells

Mr. Kostrzewa served as assistant general counsel at the Office of the U.S. Trade Representative (USTR), where he...  |  Read More

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