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The American Chamber of Commerce in Shanghai's Legal Committee invites you to an informative session on Thursday, May 14, from 10:00 a.m. to 11:30 a.m. at the Chamber's conference room. This session will provide an in-depth interpretation of two recently issued regulations by the PRC State Council: the Provisions on the Security of Industrial and Supply Chains (effective March 31, 2026) and the Regulations on Countering Foreign Improper Extraterritorial Jurisdiction (effective April 13, 2026).
These new rules are designed to (1) ensure continuity and security of supply chains, especially in key industries, and (2) counter the impact of foreign laws applied extraterritorially to PRC entities, e.g., U.S. sanctions and export control laws. As a result, multinational companies in China face increasing "dual compliance" challenges, managing conflicting regulatory requirements across jurisdictions.
Key implications include:
โข Existing supplier due diligence processes (e.g., supply chain transparency requirements) may conflict with the new rules.
โข Compliance with foreign sanctions and export control regimes may carry increased legal risk.
โข Cross-border data transfers related to compliance audits, internal investigations, or global reporting may face additional restrictions.
โข Global compliance frameworks may require adjustment to align with evolving PRC regulatory expectations.
In this session, our speaker Ron Cai, Senior Cousnel of Zhong Lun Law Firm will provide an overview of the key features of these new rules. He will also discuss how these new rules may affect MNCs' compliance practices, particularly in supply chain operations, due diligence process, data handling, and cross-border data flows.


