NO LIMITS Act of 2025
- Bill Number
- H.R. 2914
- Origin Chamber
- House
- Congress
- 119th Congress, Session 1
- Policy Area
- International Affairs
- Status
- Introduced
- Latest Action
- 2025-04-14: Referred to the House Committee on Foreign Affairs.
- Last Updated
- 2025-05-27T15:53:07Z
AI-Generated Summary
Purpose of the Legislation
The NO LIMITS Act of 2025 aims to counter the People's Republic of China's (PRC) support for Russia's invasion of Ukraine by authorizing new sanctions on PRC entities involved in Russia's military and technology sectors. It seeks to protect U.S. national security by restricting financial and material support to Russia's war efforts and addressing PRC's military modernization, which blurs lines between civilian and military activities.
Key Provisions
- Findings and Sense of Congress (Section 2): Congress recognizes evidence of PRC companies evading U.S. sanctions to aid Russia's defense industry (e.g., specific designations of Sinno Electronics and Spacety China). It expresses that PRC support enables Russia's invasion and urges the President to cut off financing for PRC entities aiding Russia, impose export controls on dual-use technology (items with both civilian and military uses) to the PRC, and sanction PRC exports of weapons or dual-use items like microelectronics and aerospace parts to Russia.
- Imposition of Sanctions (Section 3):
- Starting 90 days after enactment, the President may block all U.S.-related property and transactions of foreign persons (non-U.S. individuals or entities) that are PRC-based and operate in Russia's technology, defense, or other specified sectors.
- Also targets PRC persons acting for PRC armed forces or intelligence in malicious cyber activities, dual-use technology development, or evading U.S. export controls/sanctions.
- Starting 180 days after enactment, sanctions apply to "known Chinese military companies" (a list of over 50 entities like Huawei, DJI, and SMIC, plus subsidiaries) with business operations in Russia.
- Sanctions use powers from the International Emergency Economic Powers Act (IEEPA), a law allowing the President to control economic transactions during national emergencies. Penalties for violations include fines and imprisonment.
- Exceptions: No sanctions for U.S. intelligence/law enforcement activities or goods importation (defined as physical articles, excluding technical data). Waivers possible for up to 90 days if vital to U.S. national interests, with congressional reporting.
- Determination on PRC Arms Manufacturers (Section 4): Within 180 days, the Treasury Secretary (in consultation with State and Defense Secretaries) must assess and report to Congress whether eight major PRC arms firms (e.g., China North Industries Group, Aviation Industry Corporation of China) warrant sanctions under Section 3 for overseas weapons sales.
- Expanding Subsidiary Controls (Section 5): Extends U.S. export licensing requirements (rules on who can receive controlled items) from the Commerce Department's Entity List to any subsidiaries or controlled entities of listed PRC or Russian firms, to prevent diversion of technology to Russia's war efforts.
- Definitions and Regulations (Sections 6-7): Defines "control" based on federal regulations (e.g., ownership or influence over an entity). Requires Commerce, Defense, and State Secretaries to issue implementing rules within 90 days.
Significant Changes to Existing Law
- Introduces mandatory timelines and specific criteria for sanctioning PRC entities linked to Russia's economy or military, expanding beyond current IEEPA uses by targeting PRC's role in Ukraine indirectly.
- Broadens the Entity List's scope to automatically include controlled subsidiaries of PRC/Russian entities, closing loopholes for evasion (previously, subsidiaries might need separate listings).
- Lists specific "known Chinese military companies" for targeted sanctions if operating in Russia, building on Executive Order 13959 (which restricted U.S. investments in PRC military-linked firms) but adding Russia-specific triggers.
- Does not limit existing presidential sanction authorities under IEEPA or other orders.
Potential Impacts
- Government Agencies: Increases workload for Treasury (sanctions implementation), State and Defense (consultations and reporting), and Commerce (export controls and regulations). Requires interagency coordination and congressional briefings, potentially straining resources.
- Citizens and Businesses: U.S. persons (citizens, residents, or U.S.-based entities) face restrictions on dealings with sanctioned PRC firms, risking penalties; this could disrupt trade in tech, aerospace, and dual-use goods, raising costs for U.S. companies reliant on PRC supply chains.
- International Relations: Heightens U.S.-PRC tensions by treating PRC support for Russia as a direct threat, possibly prompting PRC retaliation like trade barriers. Supports Ukraine by pressuring Russia's supply lines but risks broader economic fallout in global markets. May strengthen U.S. alliances (e.g., with Europe) against Russia-PRC ties.
Main Stakeholders Affected
- U.S. Government: Executive branch agencies (Treasury, State, Commerce, Defense) for enforcement; Congress (specific committees like Foreign Affairs and Intelligence) for oversight and reporting.
- PRC Entities: Military companies (e.g., Huawei, AVIC), tech firms, and arms exporters face asset freezes, transaction bans, and export restrictions, limiting global operations.
- Russian Entities: Indirectly hit through disrupted PRC supplies to Russia's defense sector, weakening its Ukraine war efforts.
- U.S. Businesses and Citizens: Exporters, investors, and consumers in affected sectors (e.g., electronics, aviation) may face compliance burdens or higher prices.
- International Actors: Ukraine benefits from reduced Russian support; allies like NATO members gain from aligned pressure on Russia-PRC axis; neutral or PRC-aligned countries could see trade disruptions.
Notable Legal, Constitutional, or Political Implications
- Legal: Relies on IEEPA for sanctions, a well-established executive tool for economic measures in emergencies, but includes waiver and exception provisions to balance flexibility. Penalties align with existing IEEPA violations, ensuring enforceability without new courts. The subsidiary expansion strengthens export control laws (e.g., Export Administration Regulations) against evasion.
- Constitutional: Upholds separation of powers by granting presidential discretion while mandating congressional reports, avoiding overreach. Potential challenges could arise on due process for sanctioned entities (e.g., blocking assets without trial), but IEEPA precedents suggest it's constitutional as a foreign affairs power.
- Political: Bipartisan introduction (Republican Moolenaar and Democrat Panetta) signals cross-party consensus on China-Russia threats. Escalates U.S. foreign policy hawkishness toward PRC, potentially influencing elections or alliances, but risks diplomatic isolation if seen as overly aggressive. No direct impact on domestic policy, focusing on international security.
This summary was generated by AI and may contain inaccuracies. Refer to the official source document for the authoritative text.
Sponsor
Rep. Moolenaar, John R. [R-MI-2]
Cosponsors (1)
Recent Actions
- 2025-04-14: Referred to the House Committee on Foreign Affairs.
- 2025-04-14: Introduced in House
- 2025-04-14: Introduced in House
Bill Versions
- NO LIMITS Act of 2025 — issued 2025-04-14 — PDF (15 pages)