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Financial Services Law Insights and Observations

OFAC amends communist Chinese military companies general license and related FAQs

Financial Crimes OFAC Department of Treasury China Sanctions Of Interest to Non-US Persons OFAC Designations

Financial Crimes

On January 27, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) issued General License (GL) 1A, “Authorizing Transactions Involving Securities of Certain Communist Chinese Military Companies,” which supersedes and replaces GL 1 (covered by InfoBytes here). GL 1A permits transactions and activities otherwise prohibited by Executive Order (E.O.) 13959 involving “publicly traded securities, or any securities that are derivative of, or are designed to provide investment exposure to such securities, of any entity whose name closely matches, but does not exactly match, the name of a Communist Chinese Military Companies List as defined by section 4(a) of E.O. 13959, as amended.” OFAC also published related frequently asked questions 878 and 879, the latter of which clarifies that GL 1A does not authorize transactions with subsidiaries of companies on the Communist Chinese Military Companies List.

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