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Chinese Military Companies Sanctions

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Non-SDN CHINESE MILITARY-INDUSTRIAL COMPLEX COMPANIES List (NS-CMIC LIST)

Frequently Asked Questions

OFAC has compiled hundreds of frequently asked questions (FAQs) about its sanctions programs and related policies.  The links below send the user to OFAC's FAQ pages. 

Interpretive Guidance

OFAC issues interpretive guidance on specific issues related to the sanctions programs it administers.  These interpretations of OFAC policy are sometimes published in response to a public request for guidance or may be released proactively by OFAC in order to address a complex topic.

Applying for a Specific OFAC License

It may be in your and the U.S. government’s interest to authorize particular economic activity related to the Chinese Military Companies Sanctions.  Certain activities related to the Chinese Military Companies Sanctions may be allowed if they are licensed by OFAC.  Visit the link below to apply for an OFAC license.

General Licenses

OFAC issues general licenses in order to authorize activities that would otherwise be prohibited with regard to the Chinese Military Companies Sanctions.  General licenses allow all US persons to engage in the activity described in the general license without needing to apply for a specific license.

Guidance on OFAC Licensing Policy

Certain activities related to the Chinese Military Companies Sanctions may be allowed if they are licensed by OFAC.  Below OFAC has issued guidance and statements on specific licensing policies as they relate to the Chinese Military Companies Sanctions.

  • Licenses for Legal Fees and Costs - Guidance on the Release of Limited Amounts of Blocked Funds for Payment of Legal Fees and Costs Incurred in Challenging the Blocking of U.S. Persons in Administrative or Civil Proceedings

LEGAL FRAMEWORK FOR Chinese Military Companies Sanctions

The Chinese Military Companies Sanctions program represents the implementation of multiple legal authorities.  Some of these authorities are in the form of executive orders issued by the President.  Other authorities are public laws (statutes) passed by The Congress.  These authorities are further codified by OFAC in its regulations which are published in the Code of Federal Regulations (CFR).  Modifications to these regulations are posted in the Federal Register.  

Executive Orders

  • 14032 - Addressing the Threat from Securities Investments that Finance Certain Companies of the People's Republic of China (June 3, 2021)
  • 13959 - Addressing the Threat from Securities Investments that Finance Communist Chinese Military Companies (November 12, 2020) 

Statutes

Code of Federal Regulations

  • 31 CFR 586 - Chinese Military-Industrial Complex Sanctions Regulations 

Federal Register Notices

  • 88 FR 60889-23 - Publication of Chinese Military- Industrial Complex Sanctions Regulations Web General Licenses 1, 1A, 1B, and 2
  • 87 FR 8735-22 - Chinese Military-Industrial Complex Sanctions Regulations