Background

The Treasury Department is prohibiting U.S. persons from purchasing or selling certain publicly traded securities connected with eight Chinese entities, as described in Executive Order 13959 as amended by EO 14032. Treasury states that these entities actively support the biometric surveillance and tracking of ethnic and religious minorities in China, particularly the predominantly Muslim Uyghur minority in Xinjiang.

EO 13959 as amended bans investments in companies deemed to have direct or indirect ties to China’s military. Specifically, U.S. citizens are barred from buying publicly traded securities of any entity determined by the Treasury Secretary, in consultation with the Secretaries of State and Defense, to be operating in the defense and related materiel sector or the surveillance technology sector of China’s economy. A new Non Specially-Designated Nationals Chinese Military-Industrial Complex Companies (NS-CMIC) List administered by the Office of Foreign Assets Control was created to implement this prohibition, which included 68 entities as of Dec. 21.

For more information on U.S. sanctions, please contact attorney Kristine Pirnia via email.

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