OFAC FAQ #865 · Chinese Military Companies Sanctions
May market intermediaries and other participants facilitate divestment from publicly traded securities of Chinese Military-Industrial Complex Companies (CMICs), including divestment by investment fund managers?
OFAC's answer
Yes. Market intermediaries, including market makers, and other participants may engage in ancillary or intermediary activities that are necessary to effect divestiture during the relevant wind-down periods or that are not otherwise prohibited under E.O. 13959, as amended. Purchases or sales by U.S. persons (including investors and intermediaries) involving investment funds that are seeking to divest during the relevant wind-down periods are permitted. See [FAQ 901](https://ofac.treasury.gov/faqs/901) with respect to the due diligence expectations associated with determining whether a particular purchase or sale is permissible.