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Financial Services Law Insights and Observations

OFAC issues FAQs on sanctioned Chinese military companies

Financial Crimes Department of Treasury OFAC Sanctions OFAC Designations China

Financial Crimes

On March 14, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) published FAQs related to two Chinese military companies sanctioned pursuant to Executive Order (E.O.) 13959, “Addressing the Threat from Securities Investments that Finance Communist Chinese Military Companies.” FAQ 880 states that, following a court order preliminarily enjoining the implementation of E.O. 13959 against a previously sanctioned company, the prohibitions are no longer applicable pending further order of the court. FAQ 881 clarifies when prohibitions in E.O. 13959 will take effect with respect to a company that was initially erroneously named, then delisted, and then correctly named.

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