The CMIC EO does not prohibit possessing CMIC securities.ĮO 13959 prohibited only purchases of CCMC covered securities. Such a gap will not affect Chinese companies listed on other sanctions lists, such as the Specifically Designated Nationals and Blocked Persons (SDN) lists.Ģ. 2 It therefore appears that for the next two months, there will be no prohibition on purchasing or selling covered securities of companies that are on both lists, and the restrictions on companies that were on the CCMC list but are not on the CMIC list are no longer in effect. The Office of Foreign Assets Control (OFAC) has removed the CCMC list from its website. The prohibitions covered by this amendment go into effect on August 2, 2021, and effective June 3, 2021, the CMIC list has replaced and superseded the CCMC list. There is a two-month gap on the prohibition on purchasing or selling covered securities from Chinese companies of concern. On the whole, there are six main takeaways when comparing the new CMIC sanctions and the CCMC sanctions:ġ. The CMIC EO results in several changes from the CCMC sanctions regime. persons from purchasing, selling, or possessing certain securities of “Communist Chinese military companies” (CCMCs). 1 Before this most recent amendment, EO 13959 banned U.S. The CMIC EO amended EO 13959 of November 12, 2020, and revoked in its entirety EO 13974 of January 13, 2021. persons from purchasing or selling certain publicly traded securities, or any publicly traded securities that are derivative of such securities or are designed to provide investment exposure to such securities (covered securities), of any listed “Chinese military industrial complex companies” (CMICs) (the CMIC EO). On June 3, 2021, President Joe Biden signed Executive Order 14032 (EO) banning U.S.
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