The US Office of Foreign Assets Control (OFAC) administers the Consolidated Sanctions List (OFAC-CSL), which previously consisted of entries from six different lists. Now another list has been added to these non-SDN lists: The Communist Chinese Military Companies List.
This US sanctions list was published pursuant to the Executive Order (EO) 13959, "Addressing the Threat from Securities Investments that Finance Communist Chinese Military Companies."
Which companies are included in the list?
The Non-SDN Communist Chinese Military Companies List contains various Communist Chinese Military Companies ("CCMCs") that are associated with the Chinese military.
What prohibitions are listed companies subject to?
The above-mentioned EO 13959 prohibits "US persons" from trading in publicly traded securities (shares, etc.) of these Chinese companies. Normal trade in goods with "Communist Chinese Military Companies" is not restricted by the listing on the Non-SDN CCMC List.
However, if the sanctioned Chinese company is also listed on another US sanctions list, please refer to the respective sanctions list for the legal consequences.
How can AEB customers screen against the Non-SDN CCMC List?
To AEB customers applies: In your sanctions list screening application, OFAC's Consolidated Sanctions Lists are generally among the lists you can screen against. As of today, the new list has also been added to the existing Non-SDN Consolidated Sanctions List by the Office of Foreign Assets Control (OFAC). With the Non-SDN Consolidated Sanctions List, the OFAC provides a consolidated list of all persons and entities of its non-SDN sanctions programs. In the AEB sanctions list portfolio you will find this list under the name "OFAC-CSL: Consolidated Sanctions List" and the abbreviation "OFAC-CSL".
To find out whether your Compliance Screening application already checks against the Non-SDN Consolidated Sanctions List, you can go to the "Compliance profile" ("Screening lists" sheet) and search for the above-mentioned sanctions list name or the abbreviation "OFAC-CSL".
Note: Likelihood of confusion
Because of the nearly identical names, the non-SDN CCMC List is often confused in practice with another US list published by the Department of Defense (DoD) and not by the Department of Commerce (OFAC): The DoD's "Communist Chinese Military Companies List."
The DoD list names several Chinese companies that also have strong ties to the Chinese military. It is intended for other US authorities to use this list to impose specific sanctions on specific Chinese companies. Therefore, selected names from the DoD list can also be found on the SDN List, Entity List, MEU List, etc. A subset of the addresses has now also been added to the non-SDN Communist Chinese Military Companies List.
Efficient sanctions list screening – How AEB can help
AEB's Compliance Screening software takes care of sanctions list screening against the new US sanctions list and does this automatically in the background – also integrated into SAP®, Salesforce, Microsoft Dynamics 365, and other ERP and CRM systems on request.
For an overview of all US sanctions lists and many other jurisdictions available in Compliance Screening, please see the Compliance Screening system description: Legal regulations and available sanctions lists.