Firm Posture & In-House Response
14. China compliance collision requires law firm personnel-risk protocols — outside advisers explicitly captured by malicious entity list
Mayer Brown's analysis of China's April 2026 Extraterritorial Jurisdiction Regulations explicitly notes that professional advisers, including law firms and accountants, who assist clients with OFAC, EU, or UK sanctions compliance may be placed on China's malicious entity list.
BY GEOPOLITICS DESK · JUNE 4, 2026 · 1 MIN READ
Mayer Brown's analysis of China's April 2026 Extraterritorial Jurisdiction Regulations explicitly notes that professional advisers, including law firms and accountants, who assist clients with OFAC, EU, or UK sanctions compliance may be placed on China's malicious entity list. Consequences can include visa refusal, denial of entry, deportation, asset freezing, restrictions on data provision, and criminal liability. Firms with China-based offices, China-facing practice groups, or lawyers who travel to China for client matters need to: audit which client representations involve China-exposed sanctions and export-control work; develop escalation protocols and governance frameworks for dual-compliance scenarios; and implement personnel-safety measures for lawyers and compliance staff with China exposure.