OFAC FAQ (Removed) # 873 - Chinese Military Companies Sanctions

Date issued: Jan. 14 2021

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TURBOFAC Commentary (182 words)

UPDATE: on June 3, 2021, the President issued EO 14032, thereby significantly altering the nature of the sanctions related to Chinese military company securities. This FAQ was removed on June 3, 2021 in light of the changes to the Chinese military company sanctions regime made by EO 14032. Unless specified otherwise, the notes below read as they did on June 3, 2021.

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Notes:

This FAQ reflects the way in which the EO amending EO 13959 altered the definition of "transaction" to explicitly cover the "sale" of covered securities. Prior to the issuance of the Jan. 13 EO amending EO 13959, the reference to otherwise prohibited "sales" in the "divestment carveout" of the EO, and FAQ # 863, suggested that sales of covered securities were, in principle, within...