China’s Arrival in the Great Sanctions Game: A Learnt Response, Made by America
| Published date | 01 March 2025 |
| DOI | http://doi.org/10.1177/23477970241298750 |
| Author | Sarah Tzinieris,Rishika Chauhan |
| Date | 01 March 2025 |
Research Article
China’s Arrival in the
Great Sanctions Game:
A Learnt Response,
Made by America
Sarah Tzinieris1 and Rishika Chauhan1
Abstract
This article examines the development of China’s sanctions legislation in an
era of strategic competition. Beijing’s new sanctions regime is informed by its
experience as a sanctionee, with much of the new legislation almost directly
mirrored on sanctions enacted against China by the West. The article seeks
to account for Beijing’s interest in pursuing a formalised approach, employing
four explanatory ‘models’, namely national security threats; retaliatory economic
competition; status-seeking and prestige; and domestic constituents. The article
argues that, despite China creating a new legislative framework, Beijing will
continue to implement informal tactics for the most part, while employing formal
measures in a targeted and measured way. Ultimately this two-pronged approach
delivers a highly effective and adaptable toolkit of statecraft for China as an
ascending power. However, there are normative implications for the orderly
conduct of global trade and political cooperation as more states enter a great
sanctions race.
Keywords
China, Anti-Foreign Sanctions Law (AFSL), sanctions, Unreliable Entities List
(UEL), coercive diplomacy, strategic competition
Introduction
Nearly three years after the People’s Republic of China (PRC) (‘China’)
promulgated its Anti-Foreign Sanctions Law (AFSL), the extent to which the new
overarching sanctions regime will be implemented remains unclear. The AFSL
Journal of Asian Security
and International Affairs
12(1) 81–108, 2025
© The Author(s) 2024
Article reuse guidelines:
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DOI: 10.1177/23477970241298750
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1 Department of War Studies, King’s College London, England, United Kingdom
Corresponding author:
Sarah Tzinieris, Department of War Studies, King’s College London, England WC2R 2LS, United
Kingdom.
E-mail: sarah.tzinieris@kcl.ac.uk
82Journal of Asian Security and International Affairs 12(1)
provides a retaliatory framework, proactive sanctions measures and blocking
statute all rolled into one (Drinhausen & Legarda, 2021), but so far, few foreign
entities have faced enforcement action. Some indication of how China intends to
use its new framework came in February 2023 when Beijing adopted another new
sanctions provision, the Unreliable Entities List (UEL), to designate two American-
based aerospace and defence companies as ‘unreliable entities’ (Reuters, 2023).
In May 2024, three more American-based firms were added to the list (Reuters,
2024). In both sets of events, Beijing appeared to claim that the firms were selling
arms to Taiwan, indicating that national security is one area where China will
be prepared to take enforcement action. Equally, Beijing appears to be treading
cautiously and taking a highly measured approach in selecting its targets, perhaps
so as not to dent broader investor confidence, which has declined in recent years
amid sharpening US–China strategic competition.
Since Donald Trump’s instigation of the China–US trade war in 2018, Beijing
has developed or revised no fewer than nine sanctions-related legislative provi-
sions, as we the authors expound in this article. China is a late player in the global
sanctions space but is fast making up for lost time—and, perhaps ironically, emu-
lating its new legislative framework on those sanctions to which it has been
historically subject to by the West, and has forcefully railed against. Although
China’s sanctions regime remains a work-in-progress, there are nonetheless
several insights to be drawn about how this tool of statecraft is being developed,
related to Beijing’s grand strategy as an emerging great power. It is also evident
that the construction of China’s retaliatory measures is directly conditioned by its
historical experience of being sanctioned by the West. China’s newfound confi-
dence in its role at the top table of international affairs translates into a strategic
approach to sanctions, viewing them as an indispensable tool of statecraft which
requires a legislative basis and domestic legitimacy.
China has a unique perspective of sanctions, being one of very few countries to
have both ample experience of being targeted by them and the economic leverage
to impose them on other states (Zhao, 2010). After being a vocal critic of sanctions
for decades on the international stage, China has since performed a complete
volte-face in three fundamental ways: by developing a comprehensive sanctions
regime underpinned by a formalised, legislative framework; by becoming more
comfortable about utilising this tool, as well as threatening its use for deterrence
value; and by explicitly signalling its policy reversal on sanctions to domestic
constituents. Yet, although Beijing has crafted an overarching sanctions regime in
law, this does not mean China has discarded its historical penchant for sanctioning
informally too.
Conceptualising China’s new approach to sanctions is crucial as this has nor-
mative impacts on how other states in the international system utilise and respond
to sanctions; there are also legal, financial and reputational implications for
foreign firms doing business in China. The contribution of our article to the liter-
ature is three-fold. First, the article analyses the development of China’s sanctions
regime, charting the historical precursors and emphasising how Beijing’s multi-
faceted approach to sanctions—that is, pursuing formal and informal measures in
parallel—is informed by its historical experience as sanctionee, underpinned by
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