OFAC FAQ (Current) # 865 - Chinese Military Companies Sanctions (All versions included)

Date issued: Jun. 03 2021

You've hit a wall. Sign in if you have an account, or learn more about TURBOFAC and subscription options.
TURBOFAC is a module of the compliance platform OverRuled. To learn more about OverRuled, visit www.overruled.com.

TURBOFAC Commentary (282 words)

Notes:

1) This is one of the eight EO 13959-related FAQs that remains on OFAC’s website after the release of EO 14032 of June 3, 2021, which substantially altered the sanctions regime pertaining to Chinese military company-related securities. The plain text view of the FAQ included the text of the FAQ as it appeared prior to June 3, 2021.

2) See section II(vii) of Consolidated Comment on the Chinese Military Companies Sanctions Under the EO Issued June 3, 2021 for discussion of the operation of the "divestment carveout."

3) Note a key difference between the original version of this FAQ and the updated version; "market makers" are now explicitly included within "market intermediaries".

4) The prohibition at section 1(a) is subject to a year-long divestment carveout. This feature...