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Decree No. 835
LegislationCN

Decree No. 835

Chinese State Council executive decree of 13 April 2026 creating a Malicious Entity List as a reserve counter-sanctions instrument against the US.

Last refreshed: 28 April 2026

Key Question

Will China activate Decree No. 835 against US firms before the 24 May OFAC deadline expires?

Timeline for Decree No. 835

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Common Questions
What is China's Decree No. 835 and what does it do?
Decree No. 835 is a Chinese State Council executive order issued on 13 April 2026 that creates a Malicious Entity List. It gives the government power to freeze assets, ban entry and restrict investment for designated foreign entities. It was issued 11 days before the US sanctioned Hengli Petrochemical.Source: Lowdown
Has China used Decree 835 against any US companies?
No. As of 28 April 2026 the decree remained unactivated. Beijing held its response to the Hengli designation at embassy-level protest without listing any US entities under the new instrument.Source: Lowdown
Why did China issue Decree 835 before the US sanctioned Hengli?
The 11-day gap between the decree's issue date (13 April) and the OFAC Hengli designation (24 April) suggests Beijing had advance intelligence of the US action and prepared its counter-sanctions framework before the designation was announced.Source: Lowdown

Background

State Council Decree No. 835 was issued on 13 April 2026 — eleven days before OFAC's Hengli designation — creating a Malicious Entity List with asset-freeze, entry-ban and investment-restriction powers, assigned to the Ministry of Justice . As of 28 April it remained unactivated; law firm Morrison Foerster published early compliance analysis .

Source Material
China anti-sanctions legal framework