Despite recent high-level U.S.-China talks, several recent developments in China have elevated international trade-related compliance risks and challenges for companies with commercial ties to mainland China or dealings with Chinese counterparties. While it is unclear the extent to which these developments move the needle in terms of practical legal and enforcement implications in China, there is little doubt Beijing is sending a clear message that it is elevating the tone and seriousness of the counter-threat against companies deemed to be complicit in implementing foreign sanctions and other measures affecting Chinese companies.
