15 September 2026 — The Wingtech case marks a notable escalation in China’s countermeasure litigation landscape. In a civil action brought under China’s Anti-Foreign Sanctions Law (AFSL), a PRC court has reportedly frozen RMB 2.14 billion (USD 318 million) in equity interests held by offshore Nexperia entities in their Chinese subsidiaries. From a PRC litigation perspective, the case highlights three issues that warrant close monitoring: the potential breadth of defendants in AFSL claims, the role of China-based assets in jurisdiction and forum strategy, and the availability of early-stage asset preservation before detailed merits review.
- Why it matters: The case shows how AFSL litigation may create practical exposure for multinationals with China-based assets, subsidiaries or business operations, even before the underlying dispute is adjudicated.
- What companies should watch: China-based assets may become a strategic pressure point in PRC countermeasure litigation: they may support jurisdictional arguments, influence forum selection, be subject to preservation, and increase litigation leverage against foreign companies, Chinese subsidiaries and potentially individual executives.
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Vivian Wu, Partner, Yun Chen, Partner, Ying Chen, Counsel and Lanxin Yang, Tianyi Xie, associate, FenXun, have co-authored this legal update.