China's Ministry of Foreign Affairs Freezes Assets and Bans Entry for Paraguayan and Belizean Ministers Under the Anti-Foreign Sanctions Law

China's Ministry of Foreign Affairs promulgated Ministry of Foreign Affairs Orders No. 21 and No. 22 on October 12. The orders state that countermeasures under the 「Anti-Foreign Sanctions Law」 will be taken against Gustavo Villate, Paraguay's Minister of Information and Communication Technologies, and Francis Fonseca, Belize's Minister of Foreign Affairs, Foreign Trade, Education, Culture, Science and Technology, of Paraguay and Belize, which have diplomatic relations with Taiwan. The Paraguayan government stated on the same day that it "rejects the sanctions," and Belize's Ministry of Foreign Affairs expressed regret over the "unilateral measures." Taiwan's Ministry of Foreign Affairs said it was grateful for the two countries' support.

The Chinese Ministry of Foreign Affairs Decision Documents

The decision document (Ministry of Foreign Affairs Order No. 22, targeting Belizean Minister Fonseca) posted on the Chinese Ministry of Foreign Affairs website at 10:05 a.m. on October 12 (Beijing time, 11:05 a.m. Korea time) cited Articles 3, 4, 6, 9, and 15 of the Anti-Foreign Sanctions Law as its basis. The measures are threefold. They are the freezing of assets such as movable and immovable property in China, a ban on transactions and cooperation with organizations and individuals in China, and refusal of visa issuance and a ban on entry (including Hong Kong and Macao). The effective date is October 12, the day of promulgation. Ministry of Foreign Affairs Order No. 21 on Paraguayan Minister Villate was also issued on the same day in the same format.

The decision documents called the two countries' relations with Taiwan the 「so-called 'diplomatic relations (邦交)'」 and claimed that the individuals targeted had harmed China's "core interests." This is the Chinese Ministry of Foreign Affairs' expression. Chinese Ministry of Foreign Affairs spokesperson Mao Ning said at the regular briefing on the same day that the two people had visited Taiwan and spread false information related to 'Chinese cyberattacks,' and that the measure would "warn others by making an example of them (以儆效尤)." The decision documents and the briefing presented no basis for that cyberattack claim.

The terminology is also noted. This measure is an administrative decision that the Chinese Ministry of Foreign Affairs calls a 「countermeasure」. It is different in nature from designation on a sanctions list by the U.S. Department of the Treasury or a criminal indictment, and the parties concerned also call this measure 「sanctions」.

The Paraguayan Government's Response

Paraguay's Ministry of Foreign Affairs stated on its official X account on the night of October 12 (22:52 Korea time) that "the Paraguayan government rejects the sanctions imposed by the People's Republic of China on Gustavo Villate, Minister of Information and Communication Technologies," and that "this creates unnecessary friction with our country". In the same post, it reaffirmed its firm support for Taiwan (the Republic of China).

https://x.com/mreparaguay/status/2109643282170986813

About 20 minutes later, Minister Villate wrote on his own X account that "Paraguay's digital infrastructure follows technological and national security standards decided sovereignly" and that "no external sanction can sway our decision." He then said, "I will accelerate all joint projects together with Taiwan".

https://x.com/gvillate/status/2109647972782719423

Subsequently, in a post titled 「A Sanction That Confirms the Path (Una sanción que confirma el camino)」 on October 15, Minister Villate himself summarized the content of the measures, saying "I cannot enter China, Hong Kong, or Macao, my assets there are frozen, and no organization can transact with me".

https://x.com/gvillate/status/2110718698742747480

The Belizean Government's Response

Belize's Ministry of Foreign Affairs posted a statement on its official X account in the early morning of October 13 (02:57 Korea time), stating that it took note of the "unilateral measures" announced by the Chinese Ministry of Foreign Affairs on October 12 against Minister Fonseca. The full text of the statement dated 11:40 a.m. on October 12, Belmopan time (GMT-6), was also posted on Belize's Ministry of Foreign Affairs website.

https://x.com/MFABelize/status/2109704991489634727

Taiwan's Ministry of Foreign Affairs Response

Taiwan's Ministry of Foreign Affairs stated in Spanish and English on October 13 that it was "encouraged by allied Paraguay's firm support in the face of the People's Republic of China's coercion and pressure". On the evening of the same day, it said it would "stand firmly beside allied Belize and Minister Fonseca against the People's Republic of China's coercive measures," and highly praised Belize's sovereign decision to maintain diplomatic relations with Taiwan. The Central News Agency reported that Taiwan's Ministry of Foreign Affairs, in response to a Central News Agency inquiry, described this measure as "interference in another country's sovereignty and foreign policy." That statement reached the public through the Central News Agency, not in a Ministry of Foreign Affairs press release.

Paraguay is the only South American country with diplomatic relations with Taiwan, having established diplomatic relations with Taiwan in 1957, and Belize established diplomatic relations with Taiwan on 1989-10-13. This is a case in which China designated incumbent ministers of governments of countries with diplomatic relations with Taiwan by individual and promulgated legal measures against them, and it is a method of imposing costs at the individual level rather than pressure between states to sever diplomatic relations.

The past precedent is 2021. The Standing Committee of China's National People's Congress passed the Anti-Foreign Sanctions Law on 2021-06-10, making it possible, when a foreign country takes discriminatory measures against China or interferes in China's internal affairs, to place related individuals and organizations on a countermeasures list and freeze assets, ban entry, and take other measures. The provisions cited by this decision document are the list designation and measure provisions of this law.

The Basis Law: Articles of the Anti-Foreign Sanctions Law

The five articles cited as the basis for the decision documents can be confirmed in the original legal text released by the Standing Committee of the National People's Congress. The articles below convey the purport of the original legal text. Article 3 provides that "when a foreign state violates international law and the basic norms of international relations to contain and suppress China, takes discriminatory restrictive measures against Chinese citizens and organizations, and interferes in internal affairs, China has the right to take corresponding countermeasures." Article 4 enables relevant departments of the State Council to place individuals and organizations that directly or indirectly participated in such measures on a 「countermeasures list」, and Article 6 enumerates refusal of visa issuance, entry bans, visa cancellation, and deportation; sealing, seizure, and freezing of assets in China; bans or restrictions on transactions and cooperation with organizations and individuals in China; and other necessary measures. Article 9 provided that the determination, suspension, change, and cancellation of the list and measures are promulgated by 「order」 by the Ministry of Foreign Affairs and others. This is the reason this measure carried a 「Ministry of Foreign Affairs Order」 number. Article 15 is a provision stating that when a foreign state, organization, or individual carries out, assists, or supports acts that harm China's sovereignty, security, and development interests, measures are taken 「by reference」 to this law.

This decision document applied three of the measures under Article 6 to the two ministers, Villate and Fonseca: asset freezing, bans on transactions and cooperation, and visa refusal and entry bans. Visa cancellation and deportation are not included. Article 5 of the law enables measures to be extended to the spouse and direct family members of a listed individual and to organizations for which that individual is a senior manager, but in the countermeasures list in the October 12 decision documents, only one name each, the ministers themselves, was listed.

What the Decision Documents Show

The decision document targeting Belize wrote in its first sentence that "in recent years, some anti-China (反華) politicians in Belize have stubbornly supported Belize maintaining so-called 'diplomatic relations' with China's Taiwan region for their own private interests." It stated that the purpose of the measures was "to safeguard national sovereignty, security, and development interests and to oppose 'Taiwan independence' separatist acts." 「Anti-China politicians」 and 「separatist acts」 are the Chinese Ministry of Foreign Affairs' characterizations, and the Belizean government did not accept them.

Procedures for Lifting the Measures

Article 7 of the law provides that decisions made by relevant departments of the State Council under Articles 4 to 6 are 「final decisions」. This means that no avenue is provided to contest them through administrative litigation or other means within China. Instead, Article 8 provided that if the circumstances that were the basis for the measures change, the relevant department may 「suspend, change, or cancel」 the measures, and in that case as well, they must be promulgated by Ministry of Foreign Affairs order in accordance with Article 9. Therefore, whether the measures against the two ministers change can be confirmed by Ministry of Foreign Affairs order numbers issued in the future.

Enforcement Procedures Added by the 2025 Implementing Regulation

There is also a document that subdivided the enforcement method at a stage prior to this Ministry of Foreign Affairs order. China's State Council promulgated the 「Implementing Regulation of the Anti-Foreign Sanctions Law」, passed at the 55th executive meeting on 2025-03-21, as State Council Order No. 803 on March 23 and implemented it on the same day. It has 22 articles in total. Article 5 required that when deciding countermeasures, the targets, the specific measures, and the implementation date be clearly stated in the decision document. The division of duties among enforcement ministries was also separated by article. Visa refusal and entry bans are handled by foreign affairs and national immigration administration departments; sealing, seizure, and freezing of assets are handled by public security, finance, natural resources, transport, customs, market supervision, financial management, and intellectual property departments; and restrictions on transactions and cooperation are handled by education, science and technology, judicial administration, ecological environment, commerce, culture and tourism, health, and sports departments by field. Article 7 stated that the scope of assets includes cash and bank deposits, securities, equity, intellectual property rights, and receivables.

A procedural exit was also newly written into this implementing regulation. Article 11 required that decisions to impose, suspend, change, or cancel measures be disclosed on the relevant ministry's official website and other channels and updated in a timely manner. Article 14 enabled organizations and individuals subject to measures to apply to the deciding ministry for suspension, change, or cancellation, while submitting the facts that they had corrected their wrongdoing and the measures taken to eliminate the consequences of their acts. Article 15 stated that a ministry may evaluate the enforcement situation and effects or review the reasons for an application and suspend, change, or cancel measures, and Article 16 provided an avenue to exceptionally carry out prohibited activities only in cases approved when there are special circumstances. The Chinese Ministry of Foreign Affairs has not disclosed whether the two ministers, Villate and Fonseca, went through this application procedure or whether it received applications from them. No subsequent Ministry of Foreign Affairs order specifying the two people, and no notice of receipt of an application, has followed the October 12 decision documents.

Grounds Stated in the Full Text of the Belize Ministry of Foreign Affairs Statement

The statement on Belize's Ministry of Foreign Affairs website developed its arguments at greater length than the X post. The statement premised that Belize is a sovereign and independent state, and wrote that under the United Nations Charter, all states have the right to conduct foreign policy without external pressure, and that sovereign equality and non-interference in the affairs of other countries are the foundation of the international order on which the security and development of small countries depend. Regarding relations with Taiwan, it explained that they were established by its own sovereign decision, and that the partnership has brought cooperation beneficial to the people of Belize in the fields of development, health, education, infrastructure, environment, and agriculture. Regarding Minister Fonseca, it drew a line that he has acted in an official capacity, under the government's instructions, for Belize's national interests.

The statement did not stop there and also stated the direction of its response. It included a sentence that this measure cannot change Belize's foreign policy and cannot prevent the government from carrying out the work entrusted to it, and that the government fully supports Minister Fonseca. It also urged all countries to refrain from unilateral coercive measures against public officials of other countries, and said it would closely consult on this matter with bilateral and regional partners and the broader international community. At the end of the statement was a promise to thank regional and international partners for their solidarity and to continue informing the people of Belize. Paraguay's Ministry of Foreign Affairs did not post a separate statement on the measure against Minister Villate on its website. Paraguay's position came in the ministry's official X post above.

Each Side's Position in One Line

• The Chinese government (Ministry of Foreign Affairs): The targeted ministers supported the "so-called diplomatic relations" with Taiwan and harmed China's core interests, so measures are taken in accordance with the Anti-Foreign Sanctions Law (10/12 decision documents and briefing).
• The governments of Paraguay, Belize, and Taiwan: The measures are rejected, and relations with Taiwan are each country's sovereign decision (10/12–13, each country's Ministry of Foreign Affairs; 10/12 and 15, Minister Villate).

What to Watch Next

• The countermeasures have been in effect since the date of promulgation (10/12), and the decision documents have no end date.
• The Chinese Ministry of Foreign Affairs had not promulgated Order No. 23, against figures from other countries with diplomatic relations with Taiwan, by the early morning of October 17.
• Paraguay's government has not disclosed specific dates for the schedule of the joint projects with Taiwan that it stated (such as the 「Yguazú Digital」 and technology park mentioned by Minister Villate).

Sources

State Council Order No. 803 of China, 「Implementing Regulation of the Anti-Foreign Sanctions Law」 (China Government Website, promulgated 2025-03-23): https://www.gov.cn/zhengce/content/202503/content_7015400.htm Chinese Ministry of Foreign Affairs Order No. 22 (Belize, Fonseca) decision document: https://www.mfa.gov.cn/wjbxw_new/202610/t20261012_12038393.shtml Chinese Ministry of Foreign Affairs Order No. 21 (Paraguay, Villate) decision document: https://www.fmprc.gov.cn/wjb_673085/zfxxgk_674865/gknrlb/fzcqdcs/202610/t20261012_12038392.shtml Chinese Ministry of Foreign Affairs 10/12 regular briefing: https://www.mfa.gov.cn/web/fyrbt_673021/202610/t20261012_12038772.shtml https://x.com/mreparaguay/status/2109643282170986813 https://x.com/gvillate/status/2109647972782719423 https://x.com/gvillate/status/2110718698742747480 https://x.com/MFABelize/status/2109704991489634727 Belize Ministry of Foreign Affairs statement: https://mfa.gov.bz/foreign-ministry-statement-on-the-measures-announced-by-the-peoples-republic-of-china-against-the-honourable-francis-fonseca/ https://x.com/MOFA_Taiwan/status/2109829885116244227 https://x.com/MOFA_Taiwan/status/2109962371028468152 Taiwan Ministry of Foreign Affairs response (Central News Agency): https://www.cna.com.tw/news/aipl/202610120248.aspx Paraguay 1957 diplomatic relations: https://www.taiwanembassy.org/py/post/7521.html Belize 1989.10.13 diplomatic relations: http://multilingual.mofa.gov.tw/web/web_UTF-8/almanac/almanac2008/html/08-1-6.htm Original text of the Anti-Foreign Sanctions Law (Standing Committee of the National People's Congress public version): http://www.npc.gov.cn/npc/c2/c30834/202106/t20210610_311892.html