On October 30 China’s Ministry of Commerce (“MOFCOM”) issued on draft Measures on Dual-use Items Export Control Investigation and Enforcement (the “Draft”), soliciting public comments until November 29, 2026. For the first time, the Draft explicitly sets out procedures for MOFCOM’s own enforcement arm, within its Bureau of Industry, Security, Import and Export Control, to enforce export control regulations through investigative measures, such as interrogation, seizure and detention of relevant items, assets, documents and facilities.…
On October 26, 2026, China’s Ministry of Commerce (“MOFCOM”) published the draft Special Provisions on the Protection of Chinese Trade Secrets, introducing a new sanctions tool targeting foreign infringement of Chinese trade secrets. Once finalized, the rules would authorize MOFCOM to impose sanctions on foreign companies, organizations and individuals where such infringement harms, or poses an actual threat to, China’s sovereignty, security or development interests. MOFCOM may initiate investigations before imposing sanctions, and third parties…
On 26 December 2023, China’s Ministry of Foreign Affairs announced new sanctions measures under the Anti-Foreign Sanctions Law against the following parties for their involvement in the imposition of US restrictive measures on Chinese entities over their links to alleged human rights abuses in the Xinjiang Uygur Autonomous Region: The sanctioned parties are prohibited from entering China (including mainland and the Hong Kong and Macao Special Administrative regions). In addition, all properties (including movable and…
China’s Export Control Law (“ECL”) came into effect on 1 December 2020, providing a framework to a series of separate administrative regulations on export controls issued prior to the law’s enactment. While no implementing rules or regulations under the ECL have been enacted since its passage into law, China’s Ministry of Commerce (“MOFCOM”) recently released Announcement No. 10 of 2021, on “Internal Compliance Guidelines on the Export of Dual-Use Items” (hereafter, the “Guidelines”) pursuant to…