China’s MOFCOM bans new US Sanctions : don’t recognize, enforce or comply

The move is aimed at safeguarding national sovereignty, security, and development interests, and protecting the legitimate rights and interests of Chinese citizens, legal persons, and other organizations. The prohibition order took effect immediately, according to MOFCOM.

The sanctions were imposed by the US on the so-called allegations of involvement in Iranian petroleum transactions. The five companies, including Hengli Petrochemical (Dalian) Refining Co and Shandong Shouguang Luqing Petrochemical Co, were put on the Specially Designated Nationals (SDN) List, which were subject to the sanction measures of freezing assets and prohibiting transactions.

The decision was made under the framework of China’s National Security Law, the Law on Foreign Relations, the Anti-Foreign Sanctions Law and its implementing provisions, as well as the Rules on Counteracting Unjustified Extraterritorial Application of Foreign Legislation and Other Measures (the 2021 Blocking Rules). It is also made after the working mechanism, established under the 2021 Blocking Rules, conducted a comprehensive assessment and confirmed that the US’ sanctions constitute improper extraterritorial application, according to the MOFCOM.

In a separate statement, a MOFCOM spokesperson stated that since 2025, the US, under its executive orders imposing sanctions on other countries, has targeted the five Chinese enterprises based on so-called allegations of their involvement in Iranian petroleum transactions. The US measures – including placement on the SDN List, asset freezes, and transaction bans – improperly prohibit or restrict normal economic and trade activities between Chinese companies and third countries (or regions) as well as their citizens, legal persons, or other organizations. Such actions violate international law and basic norms governing international relations, according to the MOFCOM spokesperson.

The Chinese government has consistently opposed unilateral sanctions that lack UN authorization and a basis in international law. The issuance of this prohibition order is a concrete action taken in accordance with the 2021 Blocking Rules and does not affect China’s performance of its international obligations or its protection of the legitimate rights and interests of foreign-invested enterprises under Chinese law, the spokesperson said.

The spokesperson added that MOFCOM will continue to closely monitor cases of improper extraterritorial application of foreign laws and measures. Where circumstances prescribed by the 2021 Blocking Rules exist, MOFCOM will carry out follow-up work in accordance with the law.