27/04/2026
Caught between a rock and a hard place
On April 13, China rolled out new counter-regulation rules that put international businesses in a genuinely uncomfortable position. Morrison Foerster recently detailed how these measures create a framework for identifying and countering what Beijing deems "improper" foreign jurisdiction.
If your company complies with Western sanctions while operating in China, Beijing can apply asset freezing, transaction bans, license revocation, visa denials, and investment restrictions. This isn't a hypothetical. It's a real trap for any company that works with partners, suppliers, or clients across multiple jurisdictions at the same time.
A standard SDN list check won't save you. A counterparty can be perfectly acceptable from a US compliance standpoint, and at the same time create serious exposure in a Chinese context. One business relationship, three different interpretations. The cost of getting it wrong can be a lost market, a damaged reputation, or worse.
What actually helps in these situations is the full picture – a deep understanding of who is behind your partner and where their interests truly lie. In a world where compliance with one jurisdiction creates liability in another, the only defensible position is knowing exactly who you're dealing with.
