The order, issued by the Ministry of Commerce on 2 May, marks China’s first known use of a formal blocking mechanism against US sanctions on domestic companies. It targets measures against Hengli Petrochemical Refinery Co, Shandong Shouguang Luqing Petrochemical Co, Shandong Jincheng Petrochemical Group Co, Hebei Xinhai Chemical Group Co and Shandong Shengxing Chemical Co. The firms had been placed under US restrictions linked to alleged purchases or processing of Iranian crude, including asset freezes and transaction bans.
The move places banks, insurers, commodity traders and shipping intermediaries in a difficult position. Compliance with Washington’s restrictions may now expose them to legal risk in China, while compliance with Beijing’s order may expose them to penalties under the US sanctions regime. For large Chinese banks with international operations, the dilemma is particularly acute because access to dollar clearing, correspondent banking and global capital markets remains central to their business.
China has long rejected unilateral US sanctions as illegitimate, especially when they apply beyond American territory. Until now, however, Beijing had often allowed major financial institutions and state-linked enterprises to quietly reduce exposure to sanctioned entities to avoid jeopardising access to the US financial system. The latest order changes that balance by instructing domestic parties not to recognise, enforce or comply with the penalties.
The legal basis lies in China’s blocking rules against what Beijing describes as unjustified extraterritorial application of foreign laws. Those rules, introduced in 2021 and strengthened by additional countermeasure regulations, allow authorities to prohibit compliance with foreign restrictions that impair normal business with third countries. The 2 May order says the US measures against the refiners improperly restrict lawful trade and harm the rights of Chinese entities.
The immediate trigger is Washington’s renewed pressure on Iranian oil revenues. Hengli’s Dalian refinery, with capacity of about 400,000 barrels per day, is among the most prominent privately owned refining assets to be targeted. US authorities have accused it of buying large volumes of Iranian crude. Hengli’s parent has denied trading with Iran and said operations remain normal.
Other sanctioned firms are part of China’s independent refining sector, often described as “teapot” refiners, clustered mainly in Shandong and surrounding provinces. These companies have become central to China’s discounted crude imports, including oil from Iran and Russia, as state refiners have generally been more cautious in handling cargoes exposed to sanctions risk.
The financial implications extend beyond the refiners themselves. Banks processing payments, lenders providing working capital, insurers covering cargoes, shipowners transporting crude and brokers arranging trades could all face competing legal obligations. International banks are likely to adopt a more conservative stance, while smaller domestic institutions may come under pressure to maintain services to companies protected by Beijing’s order.
Hengli has already moved to limit operational disruption. Its Singapore trading unit was restructured after the US designation, with a majority stake transferred to a company linked to a local government entity in Dalian. The shift has not fully reassured counterparties, as brokers and financial institutions remain wary of dealing with entities connected to sanctioned operations.
The confrontation comes as energy markets are adjusting to tighter enforcement against Iranian crude flows. China remains Iran’s largest oil customer, with independent refiners attracted by discounted barrels at a time when domestic margins are under pressure. Traders have reported that cargoes are often routed through complex shipping arrangements, with documentation obscuring origin and payments settled through non-dollar channels.
For Beijing, the order is also a political signal. It asserts that China will not automatically absorb the costs of US secondary sanctions when strategic commodities, energy security and private industrial champions are involved. It also offers reassurance to domestic firms that the government is prepared to use legal instruments rather than limit itself to diplomatic protest.
For Washington, the step complicates enforcement. Sanctions work most effectively when banks and intermediaries avoid designated firms without needing direct prosecution. If China compels non-compliance at home, US authorities may have to decide whether to escalate against financial institutions that continue servicing the refiners, a move that could widen the dispute from energy trade into the banking system.
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