The draft law further undermines China’s efforts to be perceived as a constructive and participatory member of the international community. The spirit and substantive provisions of the draft are consistent with the intensifying trend of broadened crackdowns on domestic civil society since President Xi Jinping assumed power in 2013. As numerous China law experts and commentators have pointed out, elements of the proposed law create serious obstacles for a functioning civil society and impede future engagement by foreign NGOs in China.[1] For instance, the lack of clarity of key terms (e.g., what constitutes a “foreign NGO,” and what “activities” fall within the law’s purview) fails to provide guidance to enforcement authorities, leaving the law vulnerable to corrupt or politicized implementation.