Overview:
The U.S. announced additional sanctions related to certain Chinese securities scheduled to go into effect on February 1, March 9, and March 15, 2021. These are an extension of the sanctions regarding other Chinese companies that went into effect on January 11. The U.S. has also recently announced that the application of sanctions against certain Chinese securities will be delayed from January 28 to May 27, 2021.
Background:
These sanctions prohibit U.S. persons from purchasing publicly traded securities, including options and other derivatives, of certain companies affiliated with the military of the People's Republic of China. We sent you this notice because you hold a position in at least one of the securities the U.S. has stated will be subject to the sanctions effective March 9, 2021.
Who will the sanctions apply to?
Currently, the sanctions only apply to "U.S. persons." A U.S. person includes, "any United States citizen, permanent resident alien, entity organized under the laws of the United States or any jurisdiction within the United States (including foreign branches), or any person in the United States." The definition of U.S. Persons includes our clients who are resident in, citizens of or incorporated in the U.S, or owned by U.S. persons.
What restrictions will the sanctions place on our Clients who are U.S. Persons?
U.S. Persons may not buy any of the sanctioned securities after the effective date of the sanctions-February 1, March 9, or March 15 as listed below-unless the purchase is to close an existing short position. They may close existing positions in these securities up until June 2, 2022 assuming the listing exchanges offer trading and the clearinghouse will settle the trades. In recognition of these actions, opening orders and inbound transfers of sanctioned securities will not be accepted, effective immediately.
What types of securities do the sanctions cover?
The sanctions cover all securities, including stocks, bonds, warrants, options and other derivatives such as ADRs. The sanctions also cover ETFs, index funds and mutual funds that include the CCMC securities.
What individual securities are subject to the sanctions?
As we noted above, sanctions on the first wave of CCMC securities went into effect on January 11, 2021. We have listed below all of the CCMC issuers whose securities are subject to sanctions and the effective date of those sanctions.
CCMC Securities
Name of Company - Effective Date
Advanced Micro-Fabrication Equipment Inc. (AMEC) - 3/15/2021
Aero Engine Corporation of China - 1/11/2021
AECC Aviation Power - 5/27/2021
Aviation Industry Corporation of China (AVIC) - 1/11/2021
Beijing Zhongguancun Development Investment Center - 3/15/2021
China Academy of Launch Vehicle Technology (CALT) - 1/11/2021
China Aerospace Science and Industry Corporation (CASIC) - 1/11/2021
China Aerospace Science and Technology Corporation (CASC) - 1/11/2021
China Communications Construction Company (CCCC) - 1/11/2021
China Construction Technology Co. Ltd. (CCTC) - 2/1/2021
China Electronics Corporation (CEC) - 1/11/2021
China Electronics Technology Group Corporation (CETC) - 1/11/2021
China General Nuclear Power Corp. - 1/11/2021
CGN Power Co. Ltd. - 5/27/2021
China International Engineering Consulting Corp. (CIECC) - 2/1/2021
China Mobile Communications Group - 1/11/2021
China Mobile LTD. - 3/9/2021
China National Aviation holding Co. Ltd. (CNAH) - 3/15/2021
China National Chemical Corporation (ChemChina) - 1/11/2021
China National Chemical Engineering Co. Ltd. - 5/27/2021
China National Chemical Engineering Group Co., Ltd. (CNCEC) - 1/11/2021
China National Nuclear Corp. - 1/11/2021
China National Nuclear Power Co. Ltd. - 5/27/2021
China National Offshore Oil Corp. (CNOOC) - 2/1/2021
CNOOC Limited - 3/9/2021
China North Industries Group Corporation (Norinco Group) - 1/11/2021
China North Industries Corp. - 5/27/2021
Norinco International Corporation Ltd. - 5/27/2021
China Nuclear Engineering & Construction Corporation (CNECC) - 1/11/2021
China Railway Construction Corporation (CRCC) - 1/11/2021
China Shipbuilding Industry Corporation (CSIC) - 1/11/2021
China Shipbuilding Industry Group Power Co. Ltd. - 5/27/2021
China South Industries Group Corporation (CSGC) - 1/11/2021
China Spacesat - 1/11/2021
China State Construction Group Co., Ltd. - 1/11/2021
China State Construction Engineering Corp. Ltd. - 5/27/2021
China State Shipbuilding Corporation (CSSC) - 1/11/2021
China Telecommunications Corp. - 1/11/2021
China Telecom Corp. Ltd. - 3/9/2021
China Three Gorges Corporation Limited - 1/11/2021
China United Network Communications Group Co. Ltd. - 1/11/2021
China United Network Communications Corp. Ltd. - 5/27/2021
China UNICOM Hong Kong Ltd. - 3/9/2021
Commercial Aircraft Corporation of China, Ltd. (COMAC) - 3/15/2021
CRRC Corp. - 1/11/2021
Dawning Information Industry Co (Sugon) - 1/11/2021
Global Tone Communication Technology Co. Ltd. (GTCOM) - 3/15/2021
GOWIN Semiconductor Corp. - 3/15/2021
Grand China Air Co. Ltd. (GCAC) - 3/15/2021
Hangzhou Hikvision Digital Technology Co., Ltd. (Hikvision) - 1/11/2021
Huawei - 1/11/2021
Inspur Group - 1/11/2021
Inspur International Ltd. - 5/27/2021
Luokong Technology Corporation (LKCO) - 3/15/2021
Offshore Oil Engineering Co. Ltd - 5/27/2021
Panda Electronics Group - 1/11/2021
Semiconductor Manufacturing International Corp. (SMIC) - 2/1/2021
Sinochem Corp. - 5/27/2021
Sinochem Group Co. Ltd. - 1/11/2021
Sinochem International Corp. - 5/27/2021
Xiaomi Corporation - 3/15/2021
We will provide you with an update if the U.S. government issues additional guidance. For reference, the U.S. Executive Order announcing the sanctions is available here and guidance provided to date is available here.