Anti-Foreign Sanctions Law
China's 2021 retaliatory law enabling countermeasures against foreign sanctions on Chinese entities.
Last refreshed: 26 April 2026 · Appears in 1 active topic
Why has China's powerful Anti-Foreign Sanctions Law barely been used despite repeated provocations?
Timeline for Anti-Foreign Sanctions Law
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Iran Conflict 2026- What is China's Anti-Foreign Sanctions Law?
- China's Anti-Foreign Sanctions Law, enacted in June 2021, gives Beijing authority to impose retaliatory countermeasures against foreign governments and entities that apply discriminatory sanctions against Chinese citizens or organisations.
- How did China use the Anti-Foreign Sanctions Law against Hengli sanctions?
- MOFCOM cited the AFSL as the legal basis for its April 2026 protest over US sanctions on Hengli Petrochemical but stopped short of activating countermeasures; analysts interpreted this as a calibrated signal rather than a full response.Source: event
- Has China ever actually activated the Anti-Foreign Sanctions Law?
- China has issued Unreliable Entity List designations and individual sanctions under related laws, but full AFSL countermeasure packages have been applied sparingly; the law is seen as a deterrent instrument more than a routinely deployed tool.
Background
The Anti-Foreign Sanctions Law (AFSL) is a piece of Chinese legislation adopted in June 2021 that gives Beijing formal legal authority to impose countermeasures against foreign governments, organisations, and individuals who apply discriminatory restrictive measures against Chinese citizens or entities. The law was enacted primarily in response to US, EU, UK, and Canadian sanctions related to Xinjiang, Hong Kong, and broader technology supply-chain disputes, and is administered primarily through MOFCOM (Ministry of Commerce) and the Ministry of Foreign Affairs.
In the context of the 2026 Iran conflict, the AFSL became relevant when US OFAC sanctioned Hengli Petrochemical, a major Chinese independent refiner, for continued purchases of Iranian crude. MOFCOM issued a formal protest through the US Embassy citing the AFSL as the legal basis for China's objection, but did not immediately activate countermeasures such as the Unreliable Entity List or asset freezes.
The AFSL includes a private right of action: Chinese nationals or entities harmed by foreign sanctions can sue the sanctioning party in Chinese courts, with damages enforceable against assets in China. This provision has so FAR seen limited practical use but represents a significant shift in China's willingness to use domestic law to push back against extraterritorial sanctions enforcement.
