The NO LIMITS Act of 2025 would give the President new, broad authority under the International Emergency Economic Powers Act to sanction Chinese entities that participate in or facilitate Russia’s war against Ukraine. It focuses on entities in China, particularly those in the technology, defense, and dual-use sectors, and also targets Chinese military companies operating in Russia. The bill creates a framework to cut off financial flows, block property, and prohibit transactions with these entities, with some narrow exceptions. It also requires a formal process to identify arms manufacturers and “known Chinese military companies,” expands licensing controls to cover subsidiaries, and directs the administration to issue implementing regulations within a few months of enactment. Overall, the measure aims to tighten U.S. and allied pressure on China to limit support for Russia’s invasion and to tighten export controls on sensitive technologies. Key features include penalties under IEEPA for violators, defined timelines for designations and studies, and explicit definitions of terms such as “foreign person,” “dual-use technology,” and “known Chinese military company.” The bill also preserves certain intelligence and law enforcement activities from sanctions and clarifies that the authority does not automatically apply to the importation of goods. If enacted, the law would deepen financial and regulatory pressure on a broad swath of Chinese firms tied to Russia’s military and defense supply chains.
Key Points
- 1Broad sanctions authority targeting PRC entities supporting Russia’s invasion, including those in the tech, defense, and dual-use sectors, with potential blocking of property and prohibition on transactions under IEEPA.
- 2The President could sanction PRC “military companies” operating in Russia within 180 days of enactment, focusing on entities with known operations in Russia and involvement in military modernization or weapons-related activities.
- 3Expansion of licensing controls to cover subsidiaries of sanctioned PRC or Russian entities, preventing diversion of restricted goods or technology through affiliated companies.
- 4Creation of a formal list of “known Chinese military companies” and a separate list of arms manufacturers (with named Chinese state-owned groups) to guide sanctions and policy actions.
- 5Regulatory implementation timeline: key federal departments (Commerce, Defense, State) must issue regulations within 90 days, with ongoing designations and determinations to be reported to Congress; waivers for national interests are allowed for up to 90-day renewable periods, and there are specific exemptions for certain intelligence/law enforcement activities and for the importation of goods.