Ed. Note: if you’re new to TURBOFAC, please take note that the text string filtration function generally shouldn’t be used for terms such as “ordinarily resident,” “causing” or “new debt”. For research on the meaning of words and phrases such as those, i.e. terms central to the key legal issues in sanctions law that appear on a cross-programmatic basis, you’re typically better off locating and checking the appropriate box in the “Key Legal Issues” search category, which will limit the results to those that have been manually assessed as being relevant for the interpretation of the terms at issue.
Try typing your search term (“ordinarily resident,” “new debt,” or something else) in the “Find a Search Filter” box at the top of the page, and the corresponding “Key Legal Issues” check box will pop up instantly, if one exists. Once you check the box (e.g. “new debt,” with ~55 results), you can always use the text string filtration function to further refine your search (e.g. by typing “invoice” and narrowing the ~55 results to ~10).
Note in addition that the same applies to text string searches such as “14071” (if you’re looking for items related to EO 14071). By typing “14071” in the “Find a Search Filter” field up top, you will be able to instantly narrow the results down to items manually assessed as relating to EO 14071. Ditto terms such as “515.204” or “Iran General License G” (try the “Discrete Legal Provision” search category).
Please contact [email protected] or [email protected] with any questions on search results and efficiency.
Please click "Apply Text String Filters" again after clicking the "Close" button immediately below.
Consolidated Comment on the Chinese Military Companies Sanctions Under EO 13959, as Amended by EO 14032 of June 3, 2021
[Update - on 2-16-2022, OFAC issued the Chinese Military-Industrial Complex Sanctions Regulations (586.201 et seq.) The issuance of the regulations does not change any of the analysis below].
BACKGROUND
The “Chinese Military Companies” EO 13959, as amended by EO 14032 of June 3, 2021, prohibits U.S. persons from engaging in the “purchase or sale of any publicly traded securities, or any publicly traded securities that are derivative of such securities or are designed to provide investment exposure to such securities,” of persons that appear on the “Non-SDN Chinese Military-Industrial Complex Companies List (NS-CMIC List)” (program tag “[CMIC-EO]”).
EO 13959 has a fairly complex history. It was first issued on November...