How China’s New Counter-Sanctions Program is Impacting Due Diligence and Compliance: Inside State Council Decrees 834 and 835
China’s counter-sanctions regime has moved from policy signal to operational reality. Decrees 834 and 835 are changing how multinational companies think about sanctions compliance, supply chain visibility, and in-country diligence. Learn what changed, what didn’t, and what teams should do now.
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The Problem
If your program still relies on supplier visits, in-country questionnaires, audits, or local investigators within China, the risk profile of that work has changed.
The recent State Council Decree 834 puts supply-chain inquiries in China under national security rules. Decree 835 authorizes retaliation over foreign sanctions enforcement and similar measures, extending to both governments and private companies. On top of that, teams still need to know who is in the supply chain, who owns them, and where state-linked, sanctions, or forced-labor exposure sits.
What You’ll Learn
- What Decrees 834 and 835 Do in Plain English The distinction between them and why it matters for private companies operating across compliance, legal, and supply chain functions.
- Which Diligence Activities Are Getting Riskier Where the immediate risk sits for private companies and which approaches remain viable.
- How to Identify State-Linked Exposure in Your Supply Chain Practical methods for mapping state-owned and state-linked entity exposure.
- Why Registry-Based Visibility Matters More Now How ownership data, customs records, and court filings sourced outside China support defensible diligence.
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See how Sayari surfaces ownership structures, sanctions exposure, and third-party risk across 250+ jurisdictions including the registries where state-owned and state-linked entities are embedded.
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