NO LIMITS Act Imposes New Financial Blockades on Chinese Companies Supporting Russia's War Effort

The NO LIMITS Act of 2025 is a sharp new tool aimed squarely at cutting off Chinese corporate support for Russia’s military operations in Ukraine. This bill gives the President significant new power to freeze assets and block transactions for any company based in the People’s Republic of China (PRC) that is found to be operating in sectors supporting Russia’s defense or technology industries. The core mechanism is a full financial block—using the International Emergency Economic Powers Act (IEEPA)—which essentially locks designated Chinese entities out of the U.S. financial system.

The New Sanctions Hammer: Who Gets Hit?

The bill creates two main ways for a Chinese company to get sanctioned. First, starting 90 days after the law passes, the President can target any PRC-based company operating in sectors supporting Russia's military, including technology and defense. Crucially, this authority extends to any other sector the Treasury or State Departments decide is "relevant." This last part is a big deal because it gives the Executive Branch a huge amount of flexibility—and potential power—to target companies that might not seem military-related on the surface, but are deemed essential to Russia’s economy (SEC. 3).

The second target, coming 180 days after enactment, are “Known Chinese military companies”—a list including giants like Huawei and SMIC—that have business operations in Russia. If you’re a U.S. company or citizen doing business with any of these sanctioned foreign persons, all transactions involving their property or interests are prohibited. If you’re a small business owner relying on a sanctioned entity for components, you’d need to find a new supplier immediately, or risk stiff fines and penalties.

Closing the Loopholes: Subsidiaries and Supply Chains

One of the smartest parts of this bill is how it deals with shell games. Under Section 5, if the U.S. government puts a Chinese or Russian company on the official “entity list” (meaning they face trade restrictions), those same restrictions automatically apply to any subsidiary or company they control. This means a sanctioned parent company can’t just spin off a new subsidiary to keep selling restricted goods. For U.S. companies that have to navigate complex global supply chains, this provision simplifies compliance, but also widens the net of who is off-limits.

However, the bill does include a significant carve-out: these new sanctions cannot be used to stop the importation of physical goods into the U.S. (SEC. 3). This is likely intended to prevent massive disruption to consumer goods and manufacturing supply chains. While the financial entities themselves are blocked, the physical flow of products—say, a shipment of consumer electronics—can continue, though the money transfer mechanism might get complicated.

The Presidential Safety Valve

While the sanctions are tough, the bill gives the President a powerful “safety valve” (SEC. 3). The President can waive the sanctions for a specific entity for 90 days at a time if they determine that doing so is “vital to U.S. national interests.” This means that if a sanction threatens to cause a major disruption—for instance, blocking a critical component used by U.S. defense contractors—the President can temporarily lift the restriction. This adds necessary flexibility but also centralizes a lot of power in the Executive Branch to decide who gets a pass and for how long.

Finally, the bill mandates a review of eight specific, major Chinese state-owned arms manufacturers, including Aviation Industry Corporation of China and China State Shipbuilding Corporation. The Treasury Secretary has 180 days to determine if these specific heavy hitters meet the criteria for sanctions. This puts some of the biggest players in the Chinese defense industry on notice right out of the gate (SEC. 4).