OrganisationUS
Morrison Foerster
Major US law firm; among the first to publish client analysis on China's Decree No. 835 and its counter-sanctions compliance implications.
Last refreshed: 28 April 2026 · Appears in 1 active topic
Key Question
What compliance trap do Morrison Foerster analysts see if China activates its Malicious Entity List?
Timeline for Morrison Foerster
#9 1 Jul
#82 26 Apr
Mentioned in: GL-V opens a 24 May Iran deadline
Iran Conflict 2026#82 13 Apr
Mentioned in: China's Decree 835 sits in reserve
Iran Conflict 2026Background
Morrison Foerster (MoFo) is a major US law firm with ~1,000 lawyers and a leading sanctions and national security practice. Its Washington DC and Hong Kong offices handle US-China trade compliance and OFAC work.
Morrison Foerster was among the first law firms to publish client advisories on Decree No. 835 and OFAC General Licence V , flagging the compliance conflict risk for multinationals if China activates its Malicious Entity List.
Common Questions
What did Morrison Foerster say about China's Decree No. 835?
Morrison Foerster published early client analysis highlighting that Decree No. 835 could create irreconcilable compliance conflicts for multinationals: companies that comply with US sanctions against Hengli could potentially be listed under China's Malicious Entity List.Source: Morrison Foerster
How the World Sees Them
China
Chinese state media has not commented on Western law firm analysis of Decree No. 835, but the Ministry of Justice will be aware that its enforcement instrument is under scrutiny.
US government
Major US law firms provide a private-sector intelligence layer on sanctions effectiveness; MoFo's rapid analysis of Decree No. 835 reached OFAC's policymakers within days.
Multinational corporations
MoFo's advisories are widely read by corporate compliance teams navigating the US-China sanctions conflict. Its analysis of Decree No. 835 flagged the potential for irreconcilable compliance obligations.