On 10 January 2021, the Ministry of Commerce of the People’s Republic of China (“MOFCOM”) promulgated the Rules on Counteracting Unjustified Extra-territorial Application of Foreign Legislation and Other Measures (the “Blocking Rules”), which came into effect the same day. The Blocking Rules were formulated in accordance with the PRC National Security Law, and aim to (amongst others) counteract the impact on Chinese companies and citizens caused by unjustified extra-territorial application of foreign legislation and other relevant measures…

On 19 September 2020, the Ministry of Commerce of the People’s Republic of China (MOFCOM) issued the Regulations on Unreliable Entity List (“UEL Regulations”), which take effect on the same date. While MOFCOM has not named any specific foreign entity to be included on the Unreliable Entity List (UEL), the UEL Regulations set out the principles for the implementation of the UEL system as summarized below. What entities will be included in the UEL? The UEL consists…