China Regulatory & Countermeasures Advisory
If your company sells to, sources from, or invests in China, you're now subject to a second rulebook — China's own. Since 2020 Beijing has built a full toolkit: export controls on critical minerals, an Unreliable Entity List, the Anti-Foreign Sanctions Law, strict data laws, and an expanded anti-espionage law. Artisan Business Group helps U.S. and international clients understand and navigate the China side of the ledger — the part most advisors don't cover.
Why the China side is now its own compliance problem
For years, "China compliance" effectively meant the U.S. rules. That's no longer enough. China has built a mirror-image regime and increasingly uses it — often in direct response to U.S. measures. The hard part is that the two systems now collide. Complying with a U.S. sanction can put you on the wrong side of China's Anti-Foreign Sanctions Law; sending data out of China to satisfy a U.S. request can breach China's data laws. You can be squeezed from both directions at once, and planning around only one side leaves you exposed on the other.
The China-side toolkit you need to plan around
Export controls & critical minerals. China licenses exports of rare earths and minerals like gallium, germanium, graphite, and antimony — imposing, tightening, and at times suspending them as geopolitical leverage. If your supply chain depends on these, availability and licensing can shift with little warning.
Countermeasures & sanctions. The Anti-Foreign Sanctions Law, the Unreliable Entity List, the blocking rules, and new 2026 counter-extraterritoriality and supply-chain-security rules can penalize a company for complying with foreign sanctions.
Data & cybersecurity. PIPL, the Data Security Law, and cross-border data-transfer approvals govern any China data you hold or move.
Anti-espionage & due-diligence risk. The 2023 anti-espionage law has broadened what counts as sensitive; ordinary in-country due diligence and information-gathering now carry real exit-ban and detention risk.
Market access & antitrust. The foreign-investment negative list, China's own national-security review, and SAMR merger review — which has blocked global deals.
How we help
We map your exposure across these regimes, tell you where the U.S. and China rules collide and what your realistic options are, prepare you to brief your board, and frame the specific questions for your licensed PRC counsel. Because the landscape moves quickly, we also monitor it on an ongoing basis. Our role is strategic advisory — we coordinate with, not replace, licensed Chinese counsel, and we work only from lawful, publicly available information.
Who this is for
U.S. and international companies that source critical minerals or components from China; that operate, invest, or hold data in China; that face the Unreliable Entity List or China's countermeasures; or that are weighing a transaction, an on-the-ground investigation, or executive travel to China.
Frequently asked questions
Isn't China compliance just about the U.S. sanctions?
Not anymore. China now has its own export controls, sanctions, data laws, and anti-espionage rules — and it uses them. Planning only around the U.S. side leaves you exposed on the other, and the two increasingly conflict.
What are China's export controls on critical minerals?
China requires licenses to export rare earths and minerals such as gallium, germanium, graphite, and antimony. It has tightened and, at times, suspended these controls as geopolitical leverage, so supply availability can change quickly and with little warning.
What are the Anti-Foreign Sanctions Law and the Unreliable Entity List?
They're China's countermeasure tools. The Anti-Foreign Sanctions Law lets China penalize those who implement foreign sanctions against it; the Unreliable Entity List can bar a foreign company from China trade and investment. Together they can turn complying with U.S. sanctions into a liability on the China side.
Is it risky to do due diligence inside China now?
It can be. The revised anti-espionage law broadened what counts as sensitive, and there have been enforcement actions against foreign consultancies and exit bans on individuals. Ordinary information-gathering has to be handled carefully and lawfully — which is exactly what we advise on.
Do you practice Chinese law?
No. We provide strategic and business advisory on the China regulatory landscape and coordinate with licensed PRC counsel for legal opinions. Think of us as your strategist and translator between the two systems, not a substitute for local lawyers.
Important Disclosures
Artisan Business Group, Inc. and Brian Su are not a licensed law firm and do not practice U.S. or Chinese (PRC) law. Nothing on this page is legal advice or a legal opinion. Our services are independent strategic, business, and regulatory advisory, coordinated with your licensed PRC and U.S. counsel, and based on lawful, publicly available information. Given China's counter-espionage and data laws, we do not conduct covert or in-country intelligence gathering. China's regulatory landscape changes rapidly; confirm current requirements with qualified counsel before acting.
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Dealing with China? Understand both rulebooks before you're caught between them.
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