How China Blocking Rules Affect Multinationals

By：Scott YU, Frank JIANG,John JIANG, Haozhe XUOn January 9, 2021, the Ministry of Commerce of the People's Republic of China (“MOFCOM”) published the Rules on Counteracting Unjustified Extra-territorial Application of Foreign Legislation and Other Measures (the “Blocking Rules”) with immediate effect. Being the No.1 Order published by MOFCOM in 2021 and following the introduction of the mechanism of the Unreliable Entity List (UEL) in September 2020,[1] the Blocking Rules reflect China’s latest effort to safeguard the interests of Chinese entities in global economic activities and as a countermeasure to the escalating U.S. long-arm jurisdictional sanctions.To manage compliance risk under the Blocking Rules, we recommend that multinational companies proactively evaluate risk exposures and formulate contingency plan, establish a firewall or fine-tune the existing arran ………………………………