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Additional Sanctions on Russia Target Chinese Entity

Monday, October 08, 2018
Sandler, Travis & Rosenberg Trade Report

The State Department has determined under the Countering America’s Adversaries Through Sanctions Act that the Chinese entity Equipment Development Department of the Central Military Commission (formerly known as the General Armaments Department) has knowingly engaged in a significant transaction with a person that is part of, or operates for or on behalf of, the defense or intelligence sectors of the Russian government. The department has therefore selected sanctions to be imposed against this entity and its director effective Sept. 20, 2018.

Under this action, U.S. government departments and agencies are prohibited from issuing any specific license or granting any other specific permission or authority under any statute that requires the prior review or approval of the U.S. government as a condition for the export or re-export of goods or technology to EDD.

In addition, with respect to both EDD and its director:

- any transactions in foreign exchange that are subject to U.S. jurisdiction and in which these entities have any interest are prohibited;

- any transfers of credit or payments between financial institutions, or by, through, or to any financial institution, to the extent that such transfers or payments are subject to U.S. jurisdiction and involve any interest of these entities, are prohibited; and

- all property and interests in property of these entities that are or come within in the U.S., or that are or come within the possession or control of any U.S. person, are blocked and may not be transferred, paid, exported, withdrawn, or otherwise dealt in.

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