MOFCOM
China's Ministry of Commerce; activates Blocking Rules to counter OFAC Iran secondary sanctions.
On 2 May, MOFCOM activated China’s Blocking Rules for five refineries facing US Iran sanctions, placing the ministry at the centre of a direct legal clash with OFAC.
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Why does MOFCOM defy OFAC publicly on mainland firms but stay silent on Hong Kong?
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MOFCOM is China’s Ministry of Commerce, the State Council ministry responsible for trade policy, foreign investment regulation and trade remedies. It administers export controls, anti-dumping work and tools used to answer foreign economic restrictions.
The ministry was formed in 2003 from the merger of the Ministry of Foreign Trade and Economic Cooperation and the State Economic and Trade Commission. Its counter-sanctions role includes the 2021 Blocking Rules, under which Chinese entities can be directed not to comply with specified foreign measures. MOFCOM used those rules against US Iran sanctions on 2 May.
That mandate makes MOFCOM a key institution in China’s economic statecraft. Its orders can place Chinese firms under Chinese legal duties that conflict with sanctions imposed elsewhere, as the five-refinery order illustrated.
MOFCOM activates its blocking rules
On 2 May, MOFCOM activated the 2021 Blocking Rules for five mainland refineries, including Hengli Petrochemical. The order barred those firms from complying with US Treasury sanctions and allowed Chinese entities to seek damages from counterparties that honoured the foreign measures.
The intervention made MOFCOM the public legal shield for mainland refiners as OFAC pressure intensified. On 25 May, China’s banking regulator ordered four state banks to stop new lending to the five refiners, showing that MOFCOM’s order did not remove the financial exposure created by US secondary sanctions.
What is MOFCOM and what does it do?
How did China respond to US sanctions on Hengli Petrochemical?
What powers does China's Anti-Foreign Sanctions Law give MOFCOM?
What is China's MOFCOM and why does it matter for Iran sanctions?
Why is China's position on Iran oil sanctions contradictory?
What is China's 2021 Blocking Rules law?
What is China's MOFCOM Blocking Rules Announcement No. 21?
Do China's Blocking Rules apply in Hong Kong?
What is the MOFCOM-NFRA split on Iran sanctions?
Written with AI from Lowdown's published reporting. Not individually reviewed by an editor. Updated 22 September 2026. Editorial standards.