OFAC permitted transactions by U.S.-operated securities exchanges involving the purchase or sale of securities related to newly listed entities on OFAC's Non-Specially Designated Nationals Communist Chinese Military Companies List ("NS-CCMC List"). General License No. 2 applies to those transactions that otherwise would be prohibited by recently amended Executive Order 13959 ("EO 13959") (see previous coverage). The authorization applies only to securities related to entities added to the NS-CCMC List after the publication of EO 13959 on November 12, 2020; the authorization does not extend to the original list of entities included in the Annex to EO 13959. The authorizations are effective for one year after the date the entity is listed on the NS-CCMC List.
In related FAQs, OFAC provided information on:
- the compliance obligations of securities exchanges operated by U.S. individuals following the amendment of EO 13959 (FAQ 871);
- the divestiture of securities holdings as required under amended EO 13959 (FAQ 872);
- the definition of the term "transaction" in the context of amended EO 13959 (FAQ 873); and
- the activities permitted to effectuate the divestitures required under amended EO 13959 (FAQ 874).
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.