Abstract: Article 4(3) of the Provisions of the State Council on Exit and Entry Administration (State Council Order No. 841) authorises the competent commerce department and other competent departments under the State Council to bar a Chinese citizen from leaving the country where that citizen has violated provisions on export control or on the administration of technology import and export and may endanger national industrial or technological security. The provision enables, for the first time, enforcement in the export control field to reach a natural person's ability to leave China without any criminal process, yet it prescribes no statutory duration and no procedure for hearing the person concerned before a decision is taken. This article advances three interpretive positions. First, the provision does not require a final administrative penalty decision or criminal judgment as a precondition; the principal ground is its regulatory purpose of immediate interdiction. Second, the absence of a statutory period cannot readily be dismissed as an oversight as a matter of interpretation, but a mechanism for periodic or application-based review should be provided as a matter of legislative policy. Third, the exception to the notification duty under Article 6 turns not on whether the subject matter belongs to the field of national security but on whether a concrete, identifiable effect exists in the individual case; otherwise the principle of notification would be displaced by the very precondition for applying Article 4(3). The outer limits of procedural protection under this provision ultimately depend on the legal character of the decision, which the text does not settle.
Keywords: exit and entry administration; export control; technology import and export; exit ban; procedural protection
1. Framing the question: a restriction on personal liberty with no statutory duration and no assured notification
Order No. 841 was adopted at the 90th executive meeting of the State Council on 29 June 2026, signed on 22 July 2026, published on 31 July 2026, and takes effect on 15 September 2026. It comprises nineteen articles. At the accompanying press briefing, officials described the legislation as responding, on an "urgent needs first" basis, to three matters: exit safety risk prevention for Chinese citizens, entry administration for foreign nationals, and regulation of exit and entry intermediary services. Public attention has concentrated on intermediary filing requirements and on grounds for refusing entry to foreign nationals.
Article 4(3) provides:
Where a Chinese citizen violates provisions on export control or on the administration of technology import and export, and may endanger national industrial security or technological security, the competent commerce department or other competent departments under the State Council may decide to bar that citizen from leaving the country.
The significance of the provision is not confined to the addition of one further ground for an exit ban under Article 12 of the Exit and Entry Administration Law. Until now, the legal consequences of export control violations attached to goods, technology and transactions and were borne by the enterprise; where a natural person's ability to leave was at stake, criminal proceedings were required, and those proceedings carry their own thresholds, statutory time limits and remedies. Under Article 4(3), a sectoral regulator may act directly on a specific individual's ability to leave without initiating any criminal process.
The allocation of the decision to the commerce authorities has a normative basis. Article 4 of the Regulations on Export Control of Dual-Use Items (State Council Order No. 792) provides that the national export control coordination mechanism organises and guides export control work for dual-use items and coordinates major matters; that the competent commerce department under the State Council is responsible for such work; and that other relevant departments are responsible for related work according to their respective functions. Order No. 841 thus places the decision with the department that already holds primary responsibility in the field. As to what "and other competent departments" encompasses, the text does not enumerate; reasoning from the allocation of functions in Article 4 of Order No. 792, it presumably refers to departments participating in export control work according to their functions, but whether the exit-ban power follows the same allocation awaits implementing rules, and no expansive reading is adopted here.
Several procedural features deserve notice. Article 4(1) and 4(2) each prescribe a statutory period of six months to three years; Article 4(3) prescribes no period at all, and no mechanism for periodic review or review upon application is apparent. Article 6 makes written notification of the facts, reasons, basis and available remedies the rule, subject to an exception where national security or a criminal investigation "may be affected"; the precondition for applying Article 4(3) is itself the possibility of endangering national industrial or technological security, so the two formulations are textually close. Article 64 of the Exit and Entry Administration Law, which makes an administrative reconsideration decision final, lists continued interrogation, detention for investigation, restriction of movement and repatriation, and does not include exit bans; a Chinese citizen subject to an exit ban is accordingly not caught by the finality rule. That last feature appears favourable to the individual, but whether it can be realised depends on whether the individual learns that a decision exists.
Taken together, Article 4(3) creates a measure that may persist indefinitely, of which the person concerned may never be notified, and for which current law provides no review, with the decision-making power vested in a sectoral regulator. What an exit ban restricts is the freedom to leave the country, and thus personal liberty; for such measures, the elements and the procedural safeguards ought to be clear. The provision is short, and both its elements and its procedural design leave room for interpretation, with the interpretive outcome determining who may be caught, how long the restriction may last, and whether the person concerned can seek any remedy.
2. The provision is a concretisation of Article 12(5) of the Exit and Entry Administration Law
Article 12 of the Exit and Entry Administration Law lists six grounds on which a Chinese citizen is not permitted to leave the country, including sub-paragraph (2) (persons serving an unexecuted criminal sentence, or defendants or suspects in criminal cases), sub-paragraph (3) (unresolved civil cases, where a court so decides), sub-paragraph (5) (persons who may endanger national security and interests, where a competent department under the State Council so decides), and sub-paragraph (6) (other circumstances provided by law or administrative regulation).
An expert commentary organised by the authorities addresses the placement of Article 4(3): Professor Cheng Xiezhong of the China University of Political Science and Law, writing on the websites of the Ministry of Justice and the National Immigration Administration, states that Article 12(5) is a general clause and that Order No. 841 gives concrete form, at the level of administrative regulation, to one of the circumstances falling within it, namely violations of export control and technology import and export rules.
This characterisation is well founded. In terms of regulatory purpose, what Article 12(5) guards against is departure that may endanger national security and interests, and technology outflow and unlicensed dual-use exports fall squarely within that description; since the Exit and Entry Administration Law took effect in 2013, no circumstance under that sub-paragraph had been given concrete form at the level of administrative regulation, and this is the first instance. In terms of legislative technique, using an administrative regulation to establish a typified circumstance with defined elements under a general enabling clause of a superior statute is conventional, and does not become unnecessary merely because the sub-paragraph already contains an authorisation. Sub-paragraph (6) simultaneously leaves an interface for administrative regulations to establish further circumstances, so Order No. 841 is not short of a basis in the hierarchy of norms. The two routes do not conflict in result, and no forced choice between them is required.
The characterisation does, however, carry a consequence for scope: the application of Article 4(3) should be constrained by the superior formulation "may endanger national security and interests", which requires that "national industrial security or technological security" be capable of subsumption within it. That subsumption is not in doubt. Article 2 of the National Security Law defines national security as a state in which the national regime, sovereignty, unity and territorial integrity, the welfare of the people, sustainable economic and social development, and other major national interests are relatively free from danger and from internal and external threat, together with the capacity to maintain that state. Industrial security and technological security fall within "sustainable economic and social development" and "other major national interests" without interpretive difficulty.
Precisely because the subsumption holds, the constraining effect of Article 12(5) on the scope of Article 4(3) is modest. It excludes only circumstances wholly unrelated to national security and interests, whereas the elements of Article 4(3) already include the possibility of endangering national industrial or technological security; the two overlap substantially in practical effect. The significance of the normative characterisation therefore lies principally in confirming the provision's place in the hierarchy of norms rather than in erecting a further substantive threshold. The boundary questions that genuinely require resolution lie in the elements themselves and in the notification duty, addressed in sections 3 and 6 below.
3. The provision does not require a final administrative penalty decision or criminal judgment as a precondition
Article 4(3) has two elements: a violation of provisions on export control or on the administration of technology import and export, and the possibility of endangering national industrial or technological security. The second is expressed as a possibility of endangerment, and is thus a risk assessment rather than an element of resulting harm; the text is clear on this point. A distinction should be drawn, however, between the character of the assessment and the clarity of its standard: how great a possibility suffices to trigger the provision is not addressed in the text, and this remains one of the matters requiring clarification.
As to the first element, the text says only "violates … provisions", without indicating whether a final administrative penalty decision or criminal judgment is required. Two readings are possible: that, the text having imposed no such requirement, the competent department may proceed once it has found a violation upon investigation; or that a finding of "violation" must still rest on a determination by an authority with competence, the text simply being silent.
A preliminary clarification is necessary. To say that Article 4(3) has "no precondition" would be inaccurate: a violation of the relevant provisions is itself the precondition. What is in issue is the form in which that precondition must be established, that is, whether it must have crystallised into a final penalty decision or judgment.
The first reading is preferable, principally on grounds of regulatory purpose. What the provision guards against is risk to technological and industrial security, and its function is immediate interdiction. Administrative penalty proceedings ordinarily take some months from initiation to a final decision, and criminal proceedings longer; if a decision to bar departure could be taken only once a penalty or judgment had become final, the person concerned would be free to leave while those proceedings ran, and since controlled technology once transferred cannot be recalled, the preventive function of the provision would be substantially defeated. Moreover, competence to find export control violations already rests with the commerce authorities; the findings made by that department in the course of investigation and the factual basis required for its exit-ban decision are cognate in terms of jurisdiction, and need not be converted through penalty proceedings.
Systematic interpretation offers only limited support here, and this should be acknowledged. Article 4(1) presupposes an administrative detention penalty already imposed; Article 4(2) presupposes verification through diplomatic missions; Article 4(3) presupposes a state of affairs in which a violation exists. The forms of the three preconditions differ in kind: the first is a past penalty, the second a verification procedure, the third a fact yet to be determined. To argue from the premise that "the first two paragraphs specify preconditions and the third alone does not" is therefore imprecise, and the contrary inference is available: since Article 4(1) takes completion of the penalty as the starting point for its period, the legislature evidently does not exclude, within this very article, a model predicated on a final penalty. The conclusion here accordingly rests mainly on purposive interpretation, with the difference between paragraphs serving only as supporting confirmation.
Nor does this reading mean that a decision may be taken without evidential foundation. "Not requiring a final penalty as a matter of form" and "not requiring a factual basis" are distinct propositions: the competent department must still have a factual basis for finding that a violation exists, though that basis need not have crystallised into a final penalty decision or judgment. Past interview records, orders to rectify within a time limit and on-site inspection records that never entered penalty proceedings may all constitute such a basis.
It should equally be acknowledged that the foregoing is an inference from text and purpose, and should not be treated as settled before implementing rules are issued. If the reading is ultimately adopted, the threshold for triggering Article 4(3) is lower than the status-based element of Article 12(2), and the question of how the resulting discretion is to be constrained becomes one for the implementing rules to answer.
4. The transfer of controlled content is not limited to documents, nor is a border crossing the sole element
Article 2(2) of the Export Control Law provides that controlled items include technical data related to those items. Article 2(3) defines export control as covering two parallel acts: transferring controlled items from within China to outside China, and Chinese citizens, legal persons and unincorporated organisations providing controlled items to foreign organisations or individuals. On its terms, the second act does not require a border crossing: a person within China who provides controlled technology to a foreign institution falls within the statute.
Article 2 of the Regulations on the Administration of Technology Import and Export, by contrast, still defines technology import and export by reference to transfer from within China to outside China, or vice versa. The reach of the two instruments therefore does not coincide: the Export Control Law's "providing to foreign organisations or individuals" may on its terms extend to provision within China, whereas the Regulations are confined to cross-border transfer. Whether a given act falls under one, or both, must be assessed separately.
As to the Regulations, Article 2 expressly lists the assignment of trade secrets and the provision of technical services as means of technology transfer, so unpatented proprietary know-how delivered to an overseas entity through personnel providing technical services may constitute a technology export; where the technology is subject to export restrictions, an application must be filed with the competent foreign trade and economic cooperation department under Article 31, and under Article 32 that department, jointly with the science and technology administration department, reviews the application and decides within thirty working days.
Arrangements that carry technology transfer through the movement of people long occupied a grey area. In practice, some enterprises have adopted workarounds along the lines of "if the equipment cannot go out, send the people; if the drawings cannot be exported, have the engineer give instructions on site". Article 13 of the Provisions of the State Council on Outbound Investment now expressly prohibits transferring prohibited goods, technology, services and related data, or transferring restricted equivalents without a licence, by means of cross-border secondment of technical personnel, organising personnel to work in other countries or regions, providing cross-border technical guidance, or arranging cross-border training. Article 4(3) attaches consequences to such conduct at the level of the individual.
Article 4(3) therefore reaches not only exporters of tangible goods but also personnel who in fact transfer controlled technology in the form of technical services or technical guidance. Compliance review cannot stop at documentary examination; it must extend to conduct as it actually occurred.
5. Application to conduct occurring before the effective date is not addressed by the text
What Article 4(3) addresses is conduct, and such conduct may have occurred before 15 September 2026. Order No. 841 contains no transitional provision, and whether and how the provision applies to conduct preceding the effective date is not specified.
On the text, what the provision establishes is not a sanction for past violations but a preventive response to risk based on an existing compliance position, its elements being directed at the state of affairs in which a violation exists rather than at the timing of the conduct; on that reading, violations occurring before the effective date may constitute the factual basis for a decision. An alternative reading is equally available: an exit ban is an adverse measure for the person concerned, and on an interpretive approach favouring the individual the provision should not be applied to pre-effective conduct. The text is silent; no conclusion is offered here beyond noting that this is among the matters implementing rules should address as a priority.
6. The absence of a statutory period: not readily an oversight as a matter of interpretation, but review should be provided as a matter of legislative policy
Article 4(1) prescribes, for those subject to administrative detention for fraudulently obtaining exit and entry documents or for unlawful exit or entry, a period of six months to three years from completion of the penalty; Article 4(2) prescribes, for those engaging in unlawful or criminal activity abroad and endangering national security and interests, a period of six months to three years from return to China; Article 4(3) prescribes no period at all.
As a matter of interpretation, deliberate omission cannot readily be ruled out. What Article 4(1) and 4(2) guard against is the risk of repeat violation, which attenuates with the passage of time, hence the fixed range; what Article 4(3) guards against is technology outflow, which once effected cannot be recalled, so that the risk does not necessarily dissipate over time. Given that difference in character, the fact that the first two paragraphs set periods while the third does not may be read as a deliberate distinction, and an analogy drawn from "the first two paragraphs both set periods" does not necessarily establish that the omission in the third is an oversight.
As a matter of legislative policy, a review mechanism should nonetheless be provided. That risk does not attenuate with time does not entail that a restriction should subsist indefinitely. Whether the risk continues depends on whether the technology remains within the scope of control and whether the person concerned remains in a position to effect a transfer; both are facts capable of periodic verification. Setting a period with review before its expiry, or permitting the person concerned to apply for review, would answer the continuing nature of the risk while subjecting the duration of the restriction to constraint. An exit ban restricts personal liberty, and the principle of proportionality requires that such restrictions be constrained in both intensity and duration; a measure with no statutory maximum, whose lifting depends entirely on the judgment of the deciding authority, and for which no review exists, lacks constraint along the temporal dimension. The objection that an administrative regulation should not establish its own review procedure, such matters being reserved to superior legislation, is not persuasive: providing a review procedure for a measure the regulation itself creates does not engage the reservation of legislative power.
Whichever reading is adopted, the present position is the same: of the three paragraphs, only the third lacks a statutory maximum, its lifting turns on the deciding authority's judgment, and no mechanism for periodic or application-based review has appeared. This is likely to be among the matters implementing rules address first.
7. The Article 6 exception turns on a concrete effect in the individual case, not on the field to which the matter belongs
Article 6(1) establishes the notification duty: for a person lawfully barred from leaving the country, the deciding authority is to notify the immigration authority for enforcement in a timely manner and to inform the person in writing of the facts, reasons, basis and available remedies; where national security or a criminal investigation may be affected, the person need not be informed. Article 6(2) further provides that, when enforcing an exit-ban decision, the immigration authority is to inform the person concerned in accordance with the content notified by the deciding authority. As a matter of regulatory design, notification is the rule and non-notification the exception.
The precondition for applying Article 4(3) is the possibility of endangering national industrial or technological security; the Article 6 exception is framed in terms of national security and criminal investigation. On the broad definition in Article 2 of the National Security Law noted above, industrial and technological security can hardly be excluded from national security. The question that arises is whether the competent department may decline to notify simply on the ground that the matter is, by its field, a national security matter. Were the answer yes, notification under this provision would become the exception to an exception.
It should not be. The element in Article 6 is not that "the matter belongs to the field of national security" but that national security "may be affected". An effect is a judgment requiring identification in the individual case: the deciding authority should be able to explain how notification itself would endanger national security, for instance by revealing the direction of an investigation, disclosing the specific content of a control list, or exposing the source of a lead. If the field to which the matter belongs were sufficient, then for every application of Article 4(3) the precondition for applying it would itself supply the ground for non-notification, and the design of Article 6, with notification as the rule and non-notification as the exception, would be displaced. An interpretation should not allow a principle to be dissolved, in a whole class of cases, by the very precondition for its application.
This position addresses the structure of the argument, not the individual case. Among cases to which Article 4(3) applies there will indeed be matters in which notification would endanger national security, and withholding notification under the exception is then unobjectionable. What is resisted is the equation of "the provision applies" with "notification may be withheld", which would relieve the deciding authority of the burden of identifying an effect in the particular case.
Non-notification restricts the procedural rights of the person concerned, and the exception should be construed strictly. The proviso in Article 6 closes with "and other circumstances", so the exception is not confined to national security; but a catch-all formulation is not itself a reason for a broader construction. If anything, the broader the catch-all, the stricter the requirement that the effect be concrete, failing which the positions of rule and exception would be inverted in practice.
On remedies, a common misconception should be dispelled. As noted in section 1, the measures for which Article 64 of the Exit and Entry Administration Law makes reconsideration final do not include exit bans, and a Chinese citizen subject to an exit ban falls outside that article, retaining the ordinary avenues under the Administrative Reconsideration Law and the Administrative Litigation Law; reconsideration of a decision by a State Council department is sought from that department, and administrative litigation lies before an intermediate people's court.
Identifying the authority is thus straightforward. The real obstacle is whether the person concerned knows of the existence and content of the decision. Where notification is withheld under the Article 6 exception, neither reconsideration nor litigation can be commenced. Where a person is stopped at the border without receiving a written document, Article 6(2) may be invoked to require the immigration authority to inform them in accordance with the content notified by the deciding authority, so as to establish the authority and the basis; where enquiries yield nothing, consideration may be given to seeking reconsideration of, or bringing proceedings against, the enforcement act of the border inspection authority, placing on the respondent or defendant the burden of adducing the decision on which enforcement rested.
By contrast, under Article 12(2) and 12(3) the deciding authority is also the authority handling the case, the decision is embedded in a procedure of which the person is ordinarily aware, and the precondition for seeking a remedy is inherently satisfied. In respect of exit bans decided in civil proceedings, applications for reconsideration to a higher people's court are attested in practice; Cai v. (application for reconsideration of an exit-ban decision) is one instance, in which the Supreme People's Court issued its decision (2021) Zui Gao Fa Min Fu No. 1 on 25 December 2021.
8. The outer limits of procedural protection depend on the legal character of the decision, which the text does not settle
What Article 6 provides is notification after the event. Whether the person concerned should be heard before a decision is taken, and whether a right to present a defence exists, are not addressed. For a restriction on liberty that may subsist indefinitely, participation before the event is more fundamental than notification after it.
Whether this gap can be filled by other legislation depends on the legal character of the decision, on which the text is silent. If it is characterised as an administrative penalty, the provisions of the Administrative Penalty Law on prior notification, the presentation of a defence and hearings would apply; Article 45 of that Law provides that a party has the right to make statements and present a defence, that the administrative organ must give full consideration to the party's views, and that it must review the facts, reasons and evidence the party puts forward. If it is characterised as an administrative compulsory measure, the procedural rules of the Administrative Compulsion Law would apply. If it is characterised as a sui generis restriction of status, then until implementing rules are issued the pre-decision procedure has no legal basis at all.
No conclusion on characterisation is offered here. It bears noting that the procedural framework applicable to the exit ban in the Cai case cited above is clear precisely because both its legal character and the procedure in which it arose were beyond doubt; the absence of characterisation under Article 4(3) is the source of the uncertainty surrounding its procedural protection.
Related to characterisation is the requirement of clarity. How broadly the element "may endanger national industrial security or technological security" extends determines directly who may be caught, and for measures restricting personal liberty clarity is an independent requirement. The position taken in section 4, that the provision has a comparatively broad reach, stands in tension with that requirement: the broader the reach, the greater the need for the element to be given concrete content. That question requires separate treatment and is noted here only.
9. Systemic position: Article 5(3) gives the three lists an enforcement outlet at the border
Article 5(3) provides that where a foreign national has been placed on a countermeasure list, an unreliable entity list or a malicious entity list, or has been subjected to countermeasures or restrictive measures, and measures such as refusal to issue exit or entry documents or refusal of entry are required by law, the immigration authority and the visa authority are to implement them according to their respective functions.
Each list has its own normative source. The countermeasure list derives from the framework of the Anti-Foreign Sanctions Law; the unreliable entity list from the Provisions on the Unreliable Entity List; and the malicious entity list is created by Article 8 of the Regulations on Countering Unwarranted Extraterritorial Application of Foreign Legislation (State Council Order No. 835), which authorises departments under the State Council to place on the list foreign organisations and individuals that promote or participate in the implementation of unwarranted extraterritorial measures, and to adopt nine categories of countermeasures and restrictive measures, including refusal to issue visas, refusal of entry, cancellation of visas and ordered departure within a time limit. Article 8(1) of Order No. 835 already contained measures such as refusal to issue visas and refusal of entry; Order No. 841 specifies that they are to be implemented by the immigration and visa authorities according to their functions, giving the effects of the lists a stable enforcement outlet at the border.
Read alongside Article 4(3), Order No. 841 establishes measures running in both directions at the level of individuals: as against foreign nationals, refusal of entry pursuant to the lists; as against Chinese citizens, an exit ban based on their compliance position under export control and technology import and export rules. Within the body of administrative regulations built up since 2026, including the Provisions of the State Council on Supply Chain and Industrial Chain Security (Order No. 834), the Regulations on Countering Unwarranted Extraterritorial Application of Foreign Legislation (Order No. 835) and the Provisions of the State Council on Outbound Investment (Order No. 837), Order No. 841 performs the enforcement function at the level of the movement of persons.
10. Conclusion: three interpretive positions, and the matters implementing rules should address first
Three positions have been advanced in respect of Article 4(3).
The provision does not require a final administrative penalty decision or criminal judgment as a precondition. The principal ground is its regulatory purpose of immediate interdiction: were a final penalty or judgment required, the preventive function would be substantially defeated. The differing forms of precondition across the three paragraphs mean that the argument from "the third alone has no precondition" should serve only as supporting confirmation. The position does not imply that a decision may rest on no factual basis; inspection and rectification records that never entered penalty proceedings may supply that basis.
The absence of a statutory period cannot readily be treated as an oversight as a matter of interpretation, since the risk against which the third paragraph guards does not attenuate with time and so differs in character from the first two. As a matter of legislative policy, however, a mechanism for periodic or application-based review should be provided, because whether the risk continues is a fact capable of verification, and because an exit ban restricts personal liberty and proportionality requires that its duration be constrained.
The exception to notification under Article 6 turns on whether a concrete, identifiable effect exists in the individual case, and not on the field to which the matter belongs. On the broad definition in Article 2 of the National Security Law, industrial and technological security can hardly be excluded from national security; precisely for that reason, permitting non-notification on the basis of field alone would allow the notification principle to be displaced by the very precondition for applying Article 4(3). The exception should be construed strictly, and the deciding authority's burden of identifying an effect in the particular case should not be relieved.
All three are inferences drawn from the text as it stands and should not be treated as settled before implementing rules are issued. Beyond the statutory period and a review mechanism, the matters implementing rules should address first include the reference of "and other competent departments", the standard for finding that endangerment "may" occur, the application of the provision to conduct preceding the effective date, and the procedure for hearing the person concerned before a decision is taken. The last of these is bound up with the legal character of the decision, which the text does not settle and on which the applicable procedural legislation depends; it is accordingly more fundamental than the others. For enterprises, pending implementing rules, the prudent course is to allow margin on the broader reading of the provision's reach, and to extend the subject of export control compliance review from goods and transactions to the personnel who in fact handle technology transfer.
The Provisions of the State Council on Exit and Entry Administration take effect on 15 September 2026. This article analyses the text of the provisions and does not constitute legal advice on any specific matter; application in any given case depends on the facts and on implementing rules yet to be issued.
Author & Team
Li RuiPartner, DeHeng Shenzhen · DeHeng Shenzhen Hengxin Legal Team (author)Finance-lease and commercial-finance disputes, investment and financing disputes, cross-border enforcement, criminal defence
Xiao HuangheGlobal Partner, DeHengMainland–Hong Kong transactions, cross-border dispute resolution and enforcement, Hong Kong-related data compliance
Lin BoPartner, DeHeng ShenzhenCommercial transaction structuring and corporate disputes
Deng ZhaowenPractising Solicitor (HK) · GBA Lawyer, DeHeng ShenzhenCommon law, Hong Kong-related enforcement and disputes
Su YingtongPractising Lawyer, DeHeng ShenzhenCriminal defence, investment and financing disputes