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Home > Export Control
Salon | How Would the Sanction on Pompeo and Blocking Measures Impact Foreign Companies and Foreign-invested Enterprises?
By Henry Chen | 2021/1/20 16:06:00

A. What background


On January 21, 2021, China imposed sanctions on 28 U.S. people who have seriously violated China's sovereignty and national security, including Pompeo, Navarro, O'Brien in the Trump administration. These people and their families have been banned from entering the mainland of China, Hong Kong and Macao. They and their affiliated enterprises and institutions have also been restricted from dealing with and doing business with China ("Sanction”).


On January 9, 2021, China’s Ministry of Commerce (“MOFCOM”) issued Measures for Blocking Improper Extraterritorial Application of Foreign Laws and Measures (“Blocking Measures”).  The Blocking Measures caused worries and panics to foreign companies (or non-Chinese companies) and foreign-invested enterprises (“FIEs”) in China.  As such, Henry Chen, a senior partner of Dentons Shanghai Office and his team, organized a workshop as titled to read into the Sanction and the Blocking Measures.


After the workshop, you will know:

--What compliance obligations are provided to Chinese companies, U.S. companies in China and U.S. companies in the U.S.?

--Would the Sanction cause secondary sanctions as well to the U.S. companies in the U.S.?

--What compliance obligations are provided under the Blocking Measures?

--Does the Blocking Measures prohibit a non-Chinese company from observing the sanction order of its home country?

--Under the Blocking Measures, a non-Chinese company could be sued as a beneficiary of a non-Chinese sanction order, would the lawsuit be feasible?

--If not feasible to sue a non-Chinese company, how about an FIE in China?

--How could a non-Chinese company and FIE manage to comply well with the Blocking Measures with business affected least?



B. Time and others


Time: 9:00-11:00 AM of February 2, 2021 Chinese time (which is 8:00-10:00 PM of February 1, 2021 New York time)


Way to dial in: Zoom


Language: English


For the compliance Salon to be held in Chinese on January 25 in the afternoon, you may follow the link to register.


C. How to register


To register to attend the workshop, please use your office email account to send an email to info@compliance.com.cn with henry.chen@dentons.cn copied.


You may use Wechat to scan the following QR code to register:



D. Speakers


Henry Chen


Licensed in China and the New York State of the US, Henry Chen is a senior partner of Dentons Shanghai Office.  Before joining Dentons, Henry was AP Compliance Director of Ford Motor Company.  


Henry has been practicing on compliance for many years with practice areas covering trade compliance, anti-corruption and anti-bribery investigation, setting up and enhancement of compliance management system, representing clients in dealing with governmental investigations.


Because of Henry’s experiences and insights on compliance, Chinese government appoints Henry Chen as a member of ISO TC309 technical committee in drafting various ISO standards including ISO 37301 Compliance Management System (which is a certifiable standard in lieu of ISO 19600 as a guidance only), ISO 37001 Anti-Bribery Management System.


Henry is the author of Compliance Risks of Enterprises in Globalization: Outbreak and Control (published by China Industrial and Commercial Publishing House in 2019) and Risk Management of Commercial Bribery in China (published by China Economic Publishing House in 2014).  


Henry is listed by Chambers Asia Pacific 2020 as a recognized lawyer for corporate investigation and anti-corruption and a recommended lawyer of The Legal 500 (2021) for Data Protection.




Link Lin


A former star debater of East China University for Political Science and Law, Link Lin provides services on trade compliance, risk management, anti-bribery and data governance.  Link was seconded to work as an a compliance in-house and gained his hands-on experiences on compliance management.



Simon Zhu


Simon worked as a Customs officer for five years and is highly knowledgeable of and experienced in Chinese trade compliance law and practice.  When working with Dentons, Simon helped handle many compliance management projects for state-owned enterprises and MNCs.

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