- within Intellectual Property, International Law, Litigation and Mediation & Arbitration topic(s)
OFAC authorized certain transactions that involve the publicly traded securities of an entity whose name "closely matches" that of a Communist Chinese military company identified in the Annex of Executive Order ("EO") 13959 ("Addressing the Threat From Securities Investments That Finance Communist Chinese Military Companies"), but that has not itself been listed on OFAC's Non-SDN Communist Chinese Military Companies List. The transactions are authorized through January 28, 2021 under General License ("GL") No. 1.
According to FAQ 858, such transactions otherwise would be prohibited by Section 1(a)(i) of EO 13959.
OFAC clarified in FAQ 865 that market intermediaries and other market participants may engage in "ancillary or intermediary activities" that are "necessary to effect" investors' divestiture from the publicly traded securities of Communist Chinese military companies during applicable wind-down periods.
Primary Sources
- OFAC General License 1: Authorizing Transactions Involving Securities of Certain Communist Chinese Military Companies
- OFAC FAQ: Chinese Military Companies Sanctions - 865
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