Scholarship on China’s Anti-Foreign Sanctions Law (AFSL) remains fragmented. It tends to address discrete questions such as the legality of unilateral sanctions, blocking mechanisms, or the counter-sanctions list, without a framework linking legislative purpose, doctrinal interpretation, and enforcement practice. Huo Zhengxin’s book fills this gap. Huo, currently Vice President of the Chinese Society of Private International Law, draws on research in international law and foreign-related rule of law, as well as experience in foreign-related legislation, treaty negotiations, and dispute resolution.

The book has three parts, with appendices containing the legislation’s full text, a statistical table of cases, and typical counter-sanctions decisions. Part I examines legislative background, purpose, and international law implications. It argues that the AFSL is defensive and reactive rather than proactive. It distinguishes between multilateral and unilateral sanctions, as well as between comprehensive and targeted smart sanctions, and explains why China’s approach is best understood as targeted smart sanctions. The legality argument proceeds on two levels: World Trade Organization (WTO) security exceptions at the treaty level and non-interference and countermeasures at the customary international law level measured against the Draft Articles on State Responsibility.

Part II interprets all 16 articles, covering triggers, targets, measures, list management, coordination, liability, judicial remedies, and umbrella authorization. Particularly useful are the discussions of Articles 4 and 5 on “basic targets plus associated extensions”, Article 6 on entry-exit, property, and transaction controls, Article 12 on recourse litigation, and Article 15 on reactive and proactive counter-sanctions. The book also compares China’s regime with the UN sanctions system, the US Office of Foreign Assets Control list, and the EU Blocking Regulation.

Part III is the book’s most distinctive contribution. It surveys enforcement practice from January 2021 to September 2024, finding that China’s counter-sanctions have been restrained, targeted, and are largely issued by the Ministry of Foreign Affairs. Effectiveness is assessed not only through economic loss but also through political signalling, corporate compliance guidance, and rights relief. The book proposes reforms in legislation, enforcement, and adjudication, including proportionality, exemptions, application in Hong Kong and Macao, inter-agency coordination, procedural standardization, and clearer rules for courts hearing sanctions-related civil cases. It also distinguishes the AFSL from the blocking rules and the unreliable entity list.

The book makes four contributions: an integrated “theory–norm–practice” framework; a China-grounded account of counter-sanctions legality; the grounding of foreign-related rule of law theory in a specific field; and a dual implementation theory of public-led counter-sanctions plus private rights relief. Its limitations are also clear. The empirical analysis relies mainly on public administrative cases, with less attention to civil judicial precedents and corporate compliance disputes. It says relatively little about digital sanctions, secondary sanctions, and cross-border data flows. Its treatment of open concepts such as “discriminatory restrictive measures” and “actual control” leaves administrative discretion and judicial review underdeveloped.

Overall, the book moves beyond conventional statutory annotation. Taking the legality of counter-sanctions and China’s institutional practice as its thread, it combines international law theory, doctrinal interpretation, empirical analysis, and reform proposals. It is a valuable work for scholars and practitioners of China’s foreign-related rule of law.