The U.S. is playing the "maximum pressure" game, but we’ve struck back with a counterpunch that hits them right where it hurts.

Ladies and gentlemen, the U.S. has recently been pulling some shenanigans, landing us in a huge mess. President Trump, with his big mouth, is always talking about “maximum pressure.” Our constructive and strategically stable relationship with the U.S. was going just fine—we even had major diplomatic plans scheduled for September—but they insisted on fabricating charges out of thin air. In July, the U.S. imposed additional tariffs on the grounds that China had failed to crack down on forced labor. Later, they expanded the Entity List by a whopping 43 companies—not only traditional industries like cotton spinning and apparel, but also high-tech sectors and strategic minerals were all blacklisted this time. But this move backfired spectacularly. Last week, the Ministry of Commerce announced countermeasures against six U.S. entities. This series of countermeasures is bold and decisive—it not only targets the purveyors of rumors regarding Xinjiang but also aims to cut off the source of the U.S.’s baseless accusations, namely, the hijacked international rules. The U.S. plays these tricks not to annoy us, but purely because it’s a low-cost strategy. The dilemma the U.S. faces is a lack of control over supply chains and uncompetitive corporate costs. It could improve its situation through self-reliance, subsidies, and the cultivation of industrial clusters, but it can also resort to bullying us. The U.S. has dominated the postwar legal order, and international rules revolve around it. When everyone acknowledges U.S. jurisdiction and its authority, it can use long-arm jurisdiction and compliance restrictions to raise the cost of international market access for Chinese enterprises. China’s countermeasures are very clear: they are not aimed at any individual politician, nor are they directed solely at the entities themselves—which are merely tools. Rather, they target the infrastructure upon which Western sanctions and trade enforcement rely. In other words, the goal is to deny the legitimacy of the United States’ approach at its very root by rejecting the validity of cross-border compliance audits. If multinational corporations continue to rigidly adhere to compliance standards, they will effectively be abandoning China’s industrial supply chain; if they wish to import critical goods, they must lower their enforcement standards. They must choose between form and substance; otherwise, they will be trying to have it both ways. This is not China’s first countermeasure. In May of this year, the Ministry of Commerce issued a blocking order in response to U.S. sanctions; the U.S. prohibited us from processing Iranian crude oil, so on what grounds should we recognize, enforce, or comply with such improper extraterritorial jurisdiction? The same applies to the EU: when it demands unnecessary domestic data from Chinese entities across borders, the Ministry of Justice has made it clear that it will not cooperate or provide such information. Western media interpret this as China beginning to erect a legal firewall to resist unilateral sanctions and long-arm jurisdiction. In fact, the gears of change in the global competitive landscape have long since begun to turn. A few days ago, *Foreign Affairs* published an article titled “China’s Legal Weapons.” It discusses how China has long elevated the strengthening of its legal capabilities to a national strategic level. Traditionally, great power competition has centered on military, economic, and technological spheres. The author argues that “legal power” can also influence the international landscape. China has long recognized that the United States can use its judicial jurisdiction to isolate Iran from the oil market and the global banking system. While this is fundamentally underpinned by wealth and military might, it also relies on U.S. legal talent, legal institutions, and judicial control over key global economic hubs. China is working to break the long-standing U.S. monopoly on global “long-arm jurisdiction” and legal hegemony through state-led legal system development. Legal hegemony is not established overnight. Its rise during World War II enabled the United States to build international security, trade, and financial institutions centered on itself—namely, the United Nations, the General Agreement on Tariffs and Trade (GATT), and the Bretton Woods system. The United States possesses a vast legal sector, mature corporate conglomerates, and a professional judicial system. These three elements reinforce one another, gradually bringing everything—including products settled in U.S. dollars, those containing American software or components, those involving U.S. entities, or those affecting the U.S. market—under U.S. jurisdiction. Many foreign companies, in order to preserve their access to the U.S. market, have chosen to comply with U.S. laws and regulations. When the United States competes with us, the referee and the player become one; laws and regulations become tools of hegemony, complementing aircraft carriers and the U.S. dollar. While appearing neutral, they are in fact all designed to uphold U.S. dominance. So how is China building its legal arsenal? There are five main dimensions: First is the rapid development of a legislative toolkit, including the National Security Law, the Anti-Foreign Sanctions Law, the Export Control Law, the Data Security Law, and others—such as measures to block sanctions, regulations to safeguard the security of industrial and supply chains, and provisions to counter improper extraterritorial jurisdiction. Not only does this form a comprehensive chain of laws and regulations, but it is also evolving toward the stages of enforcement and judicial application. Second is the development of legal talent and institutional capacity. Government ministries, law schools, and bar associations across the country are vigorously cultivating professionals in foreign-related legal affairs who are well-versed in foreign and international law, with a particular emphasis on enhancing their ability to use legal terminology from foreign legal systems in legal arguments. At the same time, efforts are being made to enhance the appeal of Chinese legal institutions—such as the China International Commercial Court and the Hong Kong International Arbitration Center—with the aim of replacing Western courts in resolving international commercial disputes. Next is providing litigation support to Chinese enterprises until they can use legal tools to break out of their historically passive position, as well as actively participating in the formulation of international rules and standards to increase their voice within the international legal system. This article argues that although China has made significant progress in building its legal capabilities, it still cannot stand on equal footing with U.S. legal hegemony. This is because, compared to legislation and governance, the so-called global credibility of the U.S. legal system is built upon its judicial independence, centuries of accumulated case law, and transparent institutional expectations. The Chinese legal system, however, is driven by political and national security demands, and this legal environment may cause multinational corporations to remain cautious. Nevertheless, the article warns the United States not to underestimate China’s legal countermeasures—particularly not to undermine the credibility of its own judicial institutions, renege on its commitments to multilateral international law, or abuse sanctions, as these actions could lead to a backlash against the U.S. dollar and the American judicial system. This self-erosion enables China to shape global legal norms and secure robust legal rights without having to embrace the liberal rule of law. No matter what the United States does, a divergence in legal and compliance systems is inevitable. This is because the backing and coercive foundation of law is state violence: if you do not comply, I can destroy you militarily, isolate you financially, and decouple from you commercially—and in that moment, I am the master of the law. When facing China, “long-arm jurisdiction” collides with the “shield of sovereignty”; unable to establish a deterrent through force, it will be rendered ineffective. However, friction will arise at the boundary between the two systems, causing the channels connecting them to fracture. Consequently, the future business world may descend into a chaotic phase akin to “two suns in the sky,” and the initial reaction of global supply chains may be to split into two independent systems. Ultimately, it will come down to which system runs more smoothly. During this period, China needs to accelerate the development of its own supply chain compliance and ESG—that is, social responsibility standards—to attract non-Western and even Western countries to join us.