OFAC authorized, through 9:30 a.m. EDT on May 27, 2021, transactions that involve the securities of an entity whose name "closely matches, but does not exactly match" that of a Communist Chinese military company ("CCMC") identified under Section 4(a) of Executive Order ("EO") 13959 ("Addressing the Threat from Securities Investments That Finance Communist Chinese Military Companies"), as amended by EO 13974.
OFAC specified that General License ("GL") No. 1A does not authorize transactions that involve the publicly traded securities, or securities that are derivative of, or designed to provide investment exposure to, such securities, of an entity specifically listed on OFAC's Non-SDN Communist Chinese Military Companies List ("NS-CCMC List"), including CNOOC Limited, China Mobile Limited, China Telecom Corporation Limited and China Unicom (Hong Kong) Limited. Pursuant to EO 13959, prohibitions related to those three companies will take effect 60 days after their addition to the NS-CCMC List on January 8, 2021 (i.e., at 9:30 a.m. EST on March 9, 2021).
GL No. 1A superseded GL No. 1 (see previous coverage here). Unlike its predecessor, GL No. 1A makes clear that the authorization applies to companies whose names are "closely matched" to entities on the NS-CCMC List, as well as to any entities named by the Department of Defense under section 4(a)(ii) of EO 13959.
Additionally, OFAC issued two related FAQs, Nos. 878 and 879, explaining the scope of GL No. 1A's authorizations.
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