China Implements Statutory Countermeasures Against United States Sanctions on Iranian Oil Refineries

中國對美國制裁伊朗煉油廠採取法定反制措施

May 7, 2026, 11:05
ChinaInternational

Introduction

The Chinese government has formally prohibited domestic entities from complying with United States sanctions targeting five refineries involved in the procurement of Iranian crude oil.

中國政府已正式禁止國內實體遵守美國針對五家參與採購伊朗原油之煉油廠的制裁。

Main Body

The Ministry of Commerce has issued a prohibition order stipulating that sanctions imposed by the US Department of the Treasury—specifically those targeting Hengli Petrochemical (Dalian) and four other refineries—shall not be recognized or enforced. This action follows US allegations that these entities facilitated the generation of substantial revenue for the Iranian military. The current directive represents the inaugural application of the 2021 'Rules on Counteracting Unjustified Extra-territorial Application of Foreign Legislation and Other Measures,' a legal framework designed to mitigate the effects of what Beijing characterizes as 'long-arm jurisdiction.'

商務部已發布禁令，規定不承認也不執行美國財政部對恆力石化（大連）及另外四家煉油廠的制裁。此舉係由於美國指控這些實體協助伊朗軍方獲取大量收入。目前的指令代表 2021 年《關於對外國不合理地採取額外管轄措施的應對辦法》的首次應用，該法律框架旨在緩解北京所定義的「長臂管轄」影響。

Under this regulatory regime, Chinese citizens and organizations affected by foreign legislation must report their status to the Ministry of Commerce within a 30-day window. Failure to comply with these reporting requirements may result in administrative penalties, including fines. Conversely, the statute permits entities that incur losses due to third-party compliance with foreign sanctions to seek judicial compensation, with the possibility of state support. This transition from ad hoc diplomatic protests to a codified legal system suggests a strategic shift toward a structural response to systemic US sanctions.

在該監管機制下，受外國法律影響的中國公民和組織必須在 30 日內向商務部申報其狀況。未能遵守這些申報要求的，可能會面臨包括罰款在內的行政處罰。相反地，該法律允許因第三方遵守外國制裁而遭受損失的實體尋求司法補償，且國家可能會提供支持。這種從臨時性外交抗議向法典化法律體系的轉型，表明在應對美國系統性制裁時，策略已轉向結構性回應。

Stakeholder positioning is currently bifurcated by market exposure. Entities with significant reliance on US dollar clearing and American financial institutions are likely to prioritize US compliance due to the immediacy of the penalties. However, state-owned enterprises and firms primarily focused on the Chinese market may find compliance with the Beijing blocking statute more viable. While some analysts suggest this model may provide a template for other sovereign states to resist unilateral measures, others contend its utility is limited for nations already severed from the US financial system.

利害關係人的定位目前根據市場曝險而分化。高度依賴美元結算和美國金融機構的實體，由於處罰的即時性，可能會優先遵守美國的規定。然而，國有企業和主要關注中國市場的公司可能會發現遵守北京的封鎖條例更為可行。雖然部分分析師認為此模式可為其他主權國家抵抗單邊措施提供範本，但也有人認為對於已被切斷與美國金融系統聯繫的國家而言，其效用有限。

Conclusion

Beijing has transitioned to a more assertive legal posture, forcing domestic and international firms to navigate conflicting regulatory mandates from the US and China.

北京已轉向更強勢的法律姿態，迫使國內外企業在美國與中國衝突的監管指令中尋求平衡。

Vocabulary Learning

The Architecture of 'Institutional Friction'

To transition from B2 to C2, a learner must move beyond mere vocabulary acquisition and begin analyzing lexical clusters—groups of words that signal a specific professional or academic register. In this text, the bridge to C2 mastery lies in the mastery of Juridico-Political Collocations.

◈ The 'Statutory' Lexical Field

Notice how the text avoids simple verbs like 'stop' or 'rule.' Instead, it employs high-precision terminology that describes the mechanism of power:

  • Codified legal system →\rightarrow (Not just 'laws,' but laws written into a formal code).
  • Regulatory regime →\rightarrow (A systemic set of rules, implying a structured environment of control).
  • Extra-territorial application →\rightarrow (The specific legal phenomenon of one country's laws affecting another's territory).
  • Bifurcated by market exposure →\rightarrow (A sophisticated way of saying 'split into two groups based on their financial risk').

◈ Semantic Precision: The 'Power' Verbs

At C2, the choice of verb must reflect the exact degree of authority. Contrast these pairings:

B2 ApproachC2 Masterclass ApproachNuance Shift
To stop/blockTo mitigate the effectsShift from total prevention to strategic reduction.
To start usingTo represent the inaugural applicationShift from action to formal, historic implementation.
To changeTo transition to a more assertive postureShift from a generic change to a calculated strategic movement.

◈ Syntactic Sophistication: The Nominalized Clause

Observe the phrase: "This transition from ad hoc diplomatic protests to a codified legal system suggests a strategic shift..."

Rather than using a verb-heavy sentence ("Because they moved from protests to laws, they are shifting strategy"), the author uses nominalization (turning actions into nouns: transition, shift). This compresses complex ideological movements into single subjects, a hallmark of C2 academic writing that allows for higher information density and a detached, objective tone.

Vocabulary Learning

prohibited (adj.)
Not allowed; forbidden.
Example:The policy explicitly prohibited the use of outdated software on company servers.
procurement (n.)
The act of obtaining or acquiring goods or services.
Example:The procurement of high‑quality raw materials is essential for the company’s production line.
facilitated (v.)
Made an action or process easier or more likely to occur.
Example:The new software facilitated faster data analysis for the research team.
substantial (adj.)
Large in amount or importance.
Example:They received substantial donations during the fundraising campaign.
inaugural (adj.)
Relating to the first or beginning of something.
Example:The inaugural ceremony marked the opening of the new research center.
mitigate (v.)
To make something less severe or harmful.
Example:The company implemented safety measures to mitigate workplace accidents.
jurisdiction (n.)
The official power to make legal decisions and judgments.
Example:The court’s jurisdiction extended only over local cases.
regulatory (adj.)
Relating to rules or laws that govern a specific activity.
Example:The regulatory framework requires strict compliance with environmental standards.
administrative (adj.)
Relating to the organization and management of a business or institution.
Example:Administrative costs accounted for a significant portion of the budget.
penalties (n.)
Punitive measures imposed for breaking rules or laws.
Example:Companies that violate the policy face heavy penalties.
incurring (v.)
To become subject to or experience something, typically a cost or loss.
Example:The project incurred unexpected expenses due to supply delays.
judicial (adj.)
Relating to courts or judges.
Example:The judicial process can take several months to resolve.
compensation (n.)
Payment or restitution for loss or injury.
Example:Employees received compensation for overtime work.
structural (adj.)
Relating to the arrangement or organization of parts within a whole.
Example:The structural changes improved the company’s efficiency.
systemic (adj.)
Involving or affecting an entire system.
Example:Systemic reforms were necessary to address the financial crisis.
bifurcated (adj.)
Divided into two branches or parts.
Example:The policy was bifurcated into domestic and international sections.
exposure (n.)
The state of being exposed to something.
Example:The company’s exposure to market volatility increased after the merger.
reliance (n.)
Dependence on or trust in someone or something.
Example:The economy’s reliance on tourism made it vulnerable to downturns.
immediacy (n.)
The quality of being immediate or urgent.
Example:The immediacy of the crisis required swift action.
viability (n.)
The ability to succeed or survive.
Example:The project’s viability was questioned by investors.
unilateral (adj.)
Carried out by one side without agreement from others.
Example:The unilateral decision upset neighboring countries.
assertive (adj.)
Confident and forceful in expressing oneself.
Example:Her assertive leadership style earned her respect.
posture (n.)
A position or stance, especially in politics or law.
Example:The government adopted a defensive posture during negotiations.
navigate (v.)
To find one’s way through or around something.
Example:She learned to navigate complex regulations in the industry.
conflicting (adj.)
Having contradictory or opposing elements.
Example:The conflicting reports made it hard to determine the truth.
mandates (n.)
Official orders or instructions.
Example:The new mandates require all employees to undergo training.
transition (n.)
The process of changing from one state to another.
Example:The transition to digital records was completed last year.
codified (adj.)
Recorded or organized into a systematic set.
Example:The codified laws were updated to reflect modern practices.
sovereign (adj.)
Having supreme power or authority.
Example:The sovereign nation exercised its rights over the disputed territory.
severed (adj.)
Cut off or disconnected.
Example:The severed connection between the two departments caused delays.
statute (n.)
A written law enacted by a legislative body.
Example:The new statute protects workers’ rights.
regime (n.)
A system or method of governance.
Example:The new regime introduced reforms in education.
framework (n.)
A structured set of ideas or rules.
Example:The policy framework guided the company’s strategy.
application (n.)
The act of putting something into use.
Example:The application of new technology improved efficiency.
characterizes (v.)
Describes or depicts the essential features.
Example:The data characterizes the trend in consumer behavior.
countermeasures (n.)
Actions taken to counter or neutralize a threat.
Example:The military developed countermeasures against cyber attacks.
counteracting (v.)
Acting against something to neutralize it.
Example:The system counteracts temperature fluctuations automatically.
extra-territorial (adj.)
Extending beyond the borders of a country.
Example:The extra-territorial jurisdiction allowed the court to prosecute the case.
unjustified (adj.)
Not based on valid reasons or evidence.
Example:The accusation was deemed unjustified by the committee.
foreign (adj.)
From another country.
Example:Foreign investors were attracted to the market.
legislation (n.)
A body of laws or statutes.
Example:The new legislation will affect small businesses.
Practice C2 words in a crossword→