Current-law scope and cautions
- The 2021 Blocking Rules require a Chinese citizen/legal person/organization encountering covered unjustified extraterritorial restrictions to report to MOFCOM within 30 days.
- Coverage is not automatic merely because a foreign sanction exists; the foreign measure must fall within the rules and be subject to Chinese working-mechanism assessment.
- The Anti-Foreign Sanctions Law and other countermeasure regimes are related but separate.
Use: This is a screening/estimation tool, not a legal opinion. Confirm the latest primary authority, regulator practice, local rules and transaction documents before acting.
