Geopolitics x Legal

Trade & Industrial Policy

China’s countermeasures create collision risk for sanctions and supply-chain diligence

Linklaters explains that China’s Decree 834 and Decree 835 create supply-chain security powers and countermeasures against foreign extraterritorial jurisdiction, including a malicious-entity list and potential restrictions on data flows, transactions, imports, exports and investment.

BY GEOPOLITICS DESK · MAY 28, 2026 · 1 MIN READ

Linklaters explains that China’s Decree 834 and Decree 835 create supply-chain security powers and countermeasures against foreign extraterritorial jurisdiction, including a malicious-entity list and potential restrictions on data flows, transactions, imports, exports and investment. Multinationals now face a legal-collision problem when foreign sanctions, export controls or due-diligence demands require actions that Chinese law may treat as improper or discriminatory.

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