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This analysis reveals how China's extraterritorial legal measures counter U.S. sanctions amid rising international tensions.
In response to President Xi Jinping’s call to accelerate its country’s law-based governance beyond its borders, China has in recent years constructed a growing suite of legal instruments with extraterritorial effect. 1 Although these measures serve multiple purposes—including facilitating China’s global expansion and protecting its overseas interests—one of their central functions is to counter U.S. sanctions and trade restrictions. 2 China’s weaponization of extraterritorial law, shaped by intensifying U.S.-China rivalry, thus represents a distinct and emerging form of extraterritoriality. It differs from the traditional expansion of extraterritorial jurisdiction, which has often operated as a form of legal imperialism in service of a broader neocolonial project. 3
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Angela Huyue Zhang (2026) studied this question.
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