OFAC FAQ #861 · Chinese Military Companies Sanctions
Does Executive Order (E.O.) 13959, as amended, prohibit U.S. persons from investing in U.S. or foreign funds, such as exchange-traded funds (ETFs) or other mutual funds, that hold publicly traded securities of a Chinese Military-Industrial Complex Company (CMIC)?
OFAC's answer
Yes. Under E.O. 13959, as amended, any purchase or sale of publicly traded securities, or any publicly traded securities that are derivative of such securities or are designed to provide investment exposure to such securities, of any CMIC listed on the NS-CMIC List is prohibited, regardless of such securities' share of the underlying index fund, ETF, or derivative thereof.