China's Anti-Sanctions Law: A New Era of Resistance to US Sanctions

The Lead

China has ordered its citizens and companies not to comply with United States sanctions against five Chinese refineries accused of handling Iranian oil, deploying a law intended to counteract 'extra-territorial' punitive measures for the first time.

Understanding China's Anti-Sanctions Order

China's Ministry of Commerce issued the 'prohibition order' after the US Department of the Treasury last month announced sanctions targeting one of China's biggest independently run 'teapot' refineries. The ministry stipulated that the US sanctions on Hengli Petrochemical (Dalian) refinery and four other refineries 'shall not be recognised, enforced or complied with'. The sanctions were deemed to 'improperly' restrict normal trade and business activities in violation of international law.

The Data Analysis

China is Iran's largest trade partner and by far the biggest buyer of Iranian oil. Chinese buyers received more than 80 percent of Iran's oil shipments in 2025, according to market intelligence firm Kpler. The US Treasury Department imposed the latest sanctions after accusing Hengli of generating hundreds of millions of dollars in revenue for Iran's military via crude oil purchases.

The Impact Analysis

The move signals that Beijing is taking a more assertive approach to countering sanctions. Companies risk facing the wrath of Washington or Beijing, depending on which measures they comply with. This potentially puts them in a difficult position, with firms likely to approach the competing pressures based on their respective levels of exposure to the US and Chinese markets.

The Prediction

China's anti-sanctions law could be seen as a model for other countries seeking to counter US pressure. However, it remains to be seen whether other countries will follow China's lead. The law's most significant long-term effect could be to inspire other powers such as Russia and the European Union to adopt similar measures.