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Thompson Hine LLP, a full-service business law firm with approximately 400 lawyers in 11 offices, was ranked number 1 in the category “Most innovative North American law firms: New working models” by The Financial Times and was 1 of 7 firms shortlisted for The American Lawyer’s inaugural Legal Services Innovation Award. The firm has been recognized by the National Law Journal as a Legal Technology Trailblazer and featured by Bloomberg for its innovative service delivery models, which drive accuracy and predictability. The firm’s commitment to innovation is embodied in Thompson Hine SmartPaTHTM – a smarter way to work – predictable, efficient and aligned with client goals. For more information, please visit ThompsonHine.com and ThompsonHine.com/SmartPaTH.

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On December 16, 2021, the Department of the Treasury&rsquo;s Office of Foreign Assets Control (OFAC) announced it was placing another eight Chinese technology firms on its Non-SDN Chinese Military-Industrial Complex Companies List (CMIC List). This action was taken pursuant to Executive Order 13959 (as amended by Executive Order 14032), which prohibits U.S. persons from conducting any transaction in publicly traded securities, or securities that are derivative of, or are designed to provide investment exposure to such securities of any companies placed on the CMIC List. According to OFAC, the eight companies being added to the list &ldquo;actively support the biometric surveillance and tracking of ethnic and religious minorities in China, particularly the predominantly Muslim Uyghur minority in Xinjiang.&rdquo; The Chinese companies are:
<ul>
<li>Cloudwalk Technology Co., Ltd.</li>
<li>Dawning Information Industry Co., Ltd.</li>
<li>Leon Technology Company Limited</li>
<li>Megvii Technology Limited</li>
<li>Netposa Technologies Limited</li>
<li>SZ DJI Technology Co., Ltd.</li>
<li>Xiamen Meiya Pico Information Co., Ltd.</li>
<li>Yitu Limited</li>
</ul>
Additional details on each of these companies are available <a href="https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20211216" target="_blank" rel="noopener">here</a>. As a result of these listings, U.S. persons will be prohibited from purchasing or selling certain publicly traded securities connected with these entities, and U.S. persons or companies holding securities in these companies must divest themselves from holdings in the CMIC listed companies no later than December 15, 2022. For additional information and details on the underlying Executive Order &ldquo;Addressing the Threat from Securities Investments that Finance Certain Companies of the People&rsquo;s Republic of China,&rdquo; see Update dated <a href="https://www.thompsonhinesmartrade.com/2021/06/biden-administration-expands-chinese-military-industrial-company-sanctions/">June 9, 2021</a>.
Note that these eight companies were already on the Department of Commerce&rsquo;s Bureau of Industry and Security (BIS) <a href="https://www.bis.doc.gov/index.php/policy-guidance/lists-of-parties-of-concern/entity-list" target="_blank" rel="noopener">Entity List</a>. Placement on the Entity List means that all exports, re-exports, or transfers of items subject to U.S. Export Administration Regulations (EAR) require a license from BIS, regardless of whether a U.S. person is involved in the transaction or whether the transaction involves the U.S. financial system.

core/freeform

SmarTrade

Senior Legislative and Regulatory Policy Advisor

Scott E. Diamond

International Trade

OFAC Identifies Eight Chinese Companies as Chinese Military-Industrial Complex Companies