NO LIMITS Act: New Bill Targets Chinese Firms Backing Russia's War, Could Freeze Assets & Disrupt Tech Supply Chains

The 'NO LIMITS Act of 2025' proposes to significantly expand the U.S. government's power to sanction Chinese individuals and companies allegedly supporting Russia's invasion of Ukraine. This legislation would authorize the President to block assets and prohibit transactions for entities connected to China that are involved in Russia's technology or defense sectors, with some measures kicking in as soon as 90 days after enactment. The core aim is to choke off financial and technological pipelines from China that are believed to be fueling Russia's military capabilities, citing concerns that Chinese entities, including civilian companies, are enabling Russia's war effort and evading existing U.S. sanctions (SEC. 2).

The Sanctions Hammer: Who's Getting Hit and How?

So, what does this actually mean? If this bill passes, the President gets the green light to impose sanctions on foreign entities based in China, or organized under Chinese law, if they're found operating in Russia's technology, defense, or related sectors (SEC. 3). This authority kicks in 90 days after the bill becomes law. The bill also targets those involved in malicious cyber activities or producing dual-use technology (items with both civilian and military applications) on behalf of the Chinese military or intelligence services.

Perhaps most notably, starting 180 days after enactment, sanctions could be slapped on a long list of specifically named 'known Chinese military companies' if they're operating in Russia. This list (SEC. 3) includes major players like Aviation Industry Corporation of China (AVIC), Huawei Technologies, Hikvision, DJI, Semiconductor Manufacturing International Corporation (SMIC), and Yangtze Memory Technologies Co. (YMTC), among many others. Being sanctioned means all their property and interests in property within U.S. reach (or controlled by U.S. persons) get blocked, and essentially all transactions are prohibited. The bill leverages powers from the International Emergency Economic Powers Act (IEEPA), and violations carry hefty penalties – think fines potentially exceeding $300,000 or twice the transaction's value, and for willful violations, fines up to $1 million and/or 20 years in prison, as outlined in IEEPA (50 U.S.C. 1705(a)).

Loopholes, Lookouts, and Wider Nets

Now, there are a few caveats. The bill includes exceptions for certain intelligence and law enforcement activities, and importantly, it generally doesn't block the importation of goods themselves, though technical data related to them could be restricted (SEC. 3). The President also has the power to waive these sanctions for renewable 90-day periods if it's deemed 'vital to U.S. national interests,' though they’d need to report this to Congress. 'Vital national interests' can be a broad term, so how this waiver is used will be something to watch.

Beyond direct sanctions, the bill tasks the Treasury Secretary, along with State and Defense, to determine within 180 days if other major Chinese arms manufacturers like China North Industries Group Corporation meet the criteria for sanctions (SEC. 4). So, that list of targeted companies could grow. Furthermore, the legislation aims to tighten the net around entities already on U.S. trade blacklists. For Chinese and Russian entities on the 'entity list,' licensing requirements for exports will now extend to any subsidiaries or entities they 'control' (SEC. 5). 'Control' here (defined by referencing 31 U.S.C. § 800.208) isn't just about owning a majority stake; it means having the power to direct key decisions of a company.

The Ripple Effect: What This Means for Business and Beyond

If you're running a business, especially one that deals with Chinese tech, manufacturing, or any of the listed companies, this bill is a big deal. The 'knowingly' standard in the bill (SEC. 3 definitions) means companies can't just plead ignorance; rigorous due diligence on supply chains and partners will become even more critical. Dealing with a company that gets sanctioned could mean frozen payments, disrupted supplies, and legal headaches.

For consumers, while the bill tries to allow for the continued importation of finished goods, disruptions in complex global supply chains are almost inevitable when major players in tech and manufacturing are targeted. This could potentially affect the availability or cost of certain electronics or other goods down the line. The government agencies involved, like the Commerce and Treasury Departments, will have 90 days after enactment to issue specific regulations on how all this will be implemented (SEC. 7), which will fill in more of the practical details. Ultimately, this act represents a significant escalation in using economic tools to address geopolitical concerns, specifically targeting the China-Russia axis, and its effects could be felt across numerous sectors.