https://xiaoxionglegal.com/en/categories/sanctions--compliance/Recent content in Sanctions & Compliance on Xiongwen NotesHugoenWed, 06 May 2026 00:00:00 +0000https://xiaoxionglegal.com/en/posts/wechat-aef03362/Wed, 06 May 2026 00:00:00 +0000https://xiaoxionglegal.com/en/posts/wechat-aef03362/On the evening of 2 May, MOFCOM Announcement No. 21 of 2026 spread quickly across compliance channels. Targeting U.S. SDN designations of five Chinese enterprises including Hengli Petrochemical (Dalian), the announcement issued a blocking order — requiring domestic actors not to recognise, enforce, or comply with the relevant U.S. measures. The text — drawing on four different statutes — does not read like an ordinary press notice. Foreign-trade and cross-border-payment practitioners reacted with the same questions: does this affect me?https://xiaoxionglegal.com/en/posts/wechat-7f1604a7/Thu, 11 Sep 2025 00:00:00 +0000https://xiaoxionglegal.com/en/posts/wechat-7f1604a7/When a Chinese enterprise is placed on a foreign sanctions list, counterparties increasingly invoke “compliance” to freeze payments, suspend supply, or refuse performance. Many enterprises assume the situation is hopeless. In fact, since the Anti-Foreign Sanctions Law (AFSL) took effect in 2021, and following the 2025 Implementing Provisions, China has built up an operable legal architecture for counter-sanctions response. In 2024 a Chinese offshore-engineering company on the U.S. OFAC SDN List used this framework to recover more than CNY 86 million in unpaid construction balances within 39 days — case (2024) Su 72 Min Chu No.https://xiaoxionglegal.com/en/posts/wechat-a602ef78/Wed, 25 Jun 2025 00:00:00 +0000https://xiaoxionglegal.com/en/posts/wechat-a602ef78/Several enquiries lately raise the same question: a long-standing foreign counterparty is suddenly placed on a U.S. sanctions list. The goods have shipped, the works are done, but the balance cannot be paid. Sometimes the foreign company itself is sanctioned; sometimes an upstream supplier has been listed and the entire chain has broken. Can the contract still be performed? Can the money still be recovered? Yes — but you need to understand and use the rules of the sanctions system itself.https://xiaoxionglegal.com/en/posts/wechat-28005b80/Sun, 23 Mar 2025 00:00:00 +0000https://xiaoxionglegal.com/en/posts/wechat-28005b80/I. Understanding the EU Forced Labour Products Regulation 1. Definition of “forced labour”. The International Labour Organization (ILO) defines forced labour as “all work or service which is exacted from any person under the menace of any penalty and for which the said person has not offered himself voluntarily”. The concept covers coercion through violence or intimidation as well as more indirect means such as debt manipulation, retention of identity documents, or threats of denunciation to immigration authorities.https://xiaoxionglegal.com/en/posts/wechat-8b333d7f/Wed, 01 Jan 2025 00:00:00 +0000https://xiaoxionglegal.com/en/posts/wechat-8b333d7f/International sanctions, typically imposed by the UN, the United States, the European Union or other states, are intended to preserve international peace and security, suppress terrorism and transnational crime, and protect human rights. For Chinese enterprises engaged in global trade, dealings with sanctioned states or entities carry significant economic, financial, reputational and operational consequences. This article analyses those consequences and offers a compliance playbook for managing risk while sustaining cross-border business.