H.R. 2914: NO LIMITS Act of 2025

This bill, known as the NO LIMITS Act of 2025, aims to impose sanctions related to the People's Republic of China (PRC) and its support for Russia's military actions, particularly in Ukraine. Here is a summary of its key provisions and objectives:

Sanction Imposition

The bill allows the President of the United States to impose sanctions on:

• Foreign entities located in China that are involved in the technology, defense, or other sectors supporting Russia's military.
• Individuals or entities acting on behalf of the Chinese government, particularly those involved in cyber activities or producing dual-use technology that could aid in military efforts.

Focus on Military Companies

Sanctions will specifically target Chinese military companies operating in Russia. These sanctions can be applied to entities identified as known Chinese military companies that conduct business in Russia.

Details of Sanctions

The sanctions will enable the U.S. government to:

• Block and prohibit transactions involving property of sanctioned entities if that property is within the United States or under U.S. control.
• Leverage the powers granted under the International Emergency Economic Powers Act to enforce these sanctions.
• Apply penalties for violations of these sanctions.

Administration of Sanctions

Regulations to implement these sanctions must be established within 90 days after the enactment of the bill. Additionally, the President has the authority to waive sanctions for up to 90 days if deemed vital to U.S. national interests.

Reporting and Oversight

Within 180 days of the bill's enactment, the Secretary of the Treasury, in consultation with other relevant secretaries, is required to report to Congress on whether specific entities meet the criteria for sanctions.

Control Over Subsidiaries

The bill clarifies that any licensing requirements imposed on PRC or Russian entities will extend to any subsidiaries controlled by those entities. This aims to prevent sanctioned entities from bypassing restrictions through indirect methods.

Definitions

The bill includes several definitions to clarify terms such as "business operations," "foreign person," and "known Chinese military company," which includes a list of specific firms within China identified as military companies.

Relevant Companies

• AVIC: Aviation Industry Corporation of China, a major defense contractor.
• SMIC: Semiconductor Manufacturing International Corporation, pivotal in China's technology sector.
• Huawei: Technology company with significant ties to the Chinese military which may be affected by sanctions on dual-use technologies.
• CGN: China General Nuclear Power Corporation, potentially involved in dual-use technologies.
• CNOOC: China National Offshore Oil Corporation, which may be impacted due to its business operations linked to national security concerns.