OFAC issues new general license and related FAQs involving Chinese military companies

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On January 14, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) issued General License (GL) 2, “Authorizing Securities Exchanges Operated by U.S. Persons to Engage in Transactions Involving Securities of Communist Chinese Military Companies.” This license permits transactions and activities otherwise prohibited by Executive Order (E.O.) 13959 (which was recently amended) involving “publicly traded securities, or any securities that are derivative of, or are designed to provide investment exposure to such securities, of any entity that is listed on the [OFAC]’s Non-SDN Communist Chinese Military Companies List (NS-CCMC List).” OFAC also published several new frequently asked questions, 871, 872, 873, 874, related to E.O. 13959.