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MOFCOM Announces Tiered Listing of 40 Japanese Entities, Significantly Tightening Japan-Related Export Compliance
On 24 February 2026, the Ministry of Commerce of the People's Republic of China ("MOFCOM") issued Announcement No.11 and Announcement No.12 of 2026, simultaneously adding a total of 40 Japanese entities to the Export Control List and the Watch List, respectively. Earlier, on 6 January 2026, MOFCOM had already issued Announcement No.1 of 2026, which imposed broader export control rules on exports of dual-use items to Japan involving Japanese military end users, military end uses, and other end users/end uses that may contribute to enhancing Japan's military capabilities. With these three regulatory measures now in effect concurrently, compliance standards applicable to China-based companies' exports to Japan have become materially more stringent, and regulatory scrutiny has tightened further. In this context, relevant companies face more severe compliance challenges and should strengthen compliance management to ensure that Japan-related export business is conducted in strict accordance with applicable laws and regulations.
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China Tightens Rules for Crypto, RWA Tokenization Included
PRC regulators have long been cautious and closely monitoring the issuance and trading of cryptocurrencies[2] since the advent of Bitcoin in 2008. Aside from the digital yuan (e-CNY) issued by the People's Bank of China ("PBoC"), China continues to reject cryptocurrencies as legal tender and strictly prohibits their circulation in the onshore market. On September 15, 2021, PBoC, along with nine other governmental, party, and judicial organs, issued the PBoC Circular [2021] No.237 (the "2021 Circular"), clearly prohibiting all onshore "cryptocurrency-related business activities". However, the 2021 Circular was silent on real-world asset ("RWA") tokenization, which has since invited curiosity from market participants.
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Key Takeaways from the Implementation Regulations of the Drug Administration Law (2026)
The current Implementation Regulations of the Drug Administration Law was first enacted in 2002 (the "2002 Regulations"), with minor amendments made in 2016, 2019, and 2024. Following the release of a draft for public comment in 2022 (the "2022 Draft"), which could refer to our article:《汉坤 • 观点 | 《药品管理法实施条例》(修订草案)重点快评》. Since 2002, the Regulations have now been comprehensively revised for the first time. The newly finalized version (the "2026 Regulations") is set to take effect on May 15, 2026. The 2026 Regulations systematically integrates over two decades of regulatory practice with the core principles of the Drug Administration Law. By providing a clear legal basis for several key regulatory mechanisms, the 2026 Regulations aims to establish a more robust and stable institutional framework for the rapidly evolving pharmaceutical industry. This article outlines and analyzes the key highlights of the 2026 Regulations, comparing them against the 2002 version and the 2022 Draft to help companies navigate the new regulatory landscape and understand its practical implications.
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Han Kun
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