OFAC issued two FAQs addressing the application of sanctions on certain Chinese military companies under Executive Order ("EO") 13959 ("Addressing the Threat From Securities Investments That Finance Communist Chinese Military Companies").

In FAQ 880, OFAC stated that, following a court order preliminarily enjoining the implementation of EO 13959 against Xiaomi Corporation, the prohibitions outlined in that EO 13959 are not currently applicable with regard to Xiaomi.

In FAQ 881, OFAC clarified that the listing of Luokong Technology Corporation pursuant to EO 13959 was erroneous. OFAC also said that Luokong Technology Corporation was delisted on March 9, 2021 and was replaced with Luokung Technology Corp. Accordingly, with respect to Luokung Technology Corp., the EO 13959 prohibitions under Section 1(a)(ii) will go into effect on May 8, 2021, and Section 1(c) will go into effect on March 9, 2022.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.