OFAC Issues General License 1A Concerning Restrictions on Communist Chinese Military Companies and Related FAQs

On January 27, 2021, the US Treasury Department’s Office of Foreign Assets Control (OFAC) issued General License 1A, “Authorizing Transactions Involving Securities of Certain Communist Chinese Military Companies,” (“GL 1A”) in relation to OFAC’s Communist Chinese Military Companies (“CCMCs”) sanctions program as implemented pursuant to Executive Order 13959 (“EO 13959”) and amended by Executive Order 13974.  OFAC concurrently published frequently asked questions (FAQs) 878 and 879, which clarify OFAC’s previous guidance on subsidiary entities with names that “closely match” the name of a CCMC.

As with the original GL 1, GL 1A authorizes US persons to engage in all transactions and activities otherwise prohibited by EO 13959 involving publicly traded securities (as well as publicly traded securities that are derivative of, or are designed to provide investment exposure to such securities) of any entity whose name “closely matches, but does not exactly match,” the name of a company on OFAC’s Non-SDN Communist Chinese Military Companies List (“NS-CCMC List”).  This authorization has been extended until 9:30 a.m. eastern daylight time on May 27, 2021 (from the original January 28, 2021 cut-off.)

See:

https://home.treasury.gov/system/files/126/ccmc_gl1a_01272021_1.pdf

https://home.treasury.gov/policy-issues/financial-sanctions/faqs/878

https://home.treasury.gov/policy-issues/financial-sanctions/faqs/879