OFAC FAQ (Current) # 905 - Chinese Military Companies Sanctions

Date issued: Jun. 03 2021

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TURBOFAC Commentary (147 words)

Notes:

1) But compare FAQ 900, suggesting that sales to and the support of undesirable activities by entities such as Huawei could result in a designation (at least for Chinese companies, and maybe others).

See also FAQ # 859, suggesting that the scope of the EO was adjusted on June 3, 2021, to remove any “note, draft, bill of exchange, or banker’s acceptance which has a maturity at the time of issuance of not exceeding 9 months, exclusive of days of grace, or any renewal thereof the maturity of which is likewise limited” from the scope of the securities covered by the order. This would have the effect of facilitating ordinary commercial trading with the entities otherwise subject to the prohibitions. Under the previous version of EO 13959, the factoring of ordinary trade receivables...