OFAC FAQ #904 · Chinese Military Companies Sanctions
Under Executive Order (E.O.) 13959, as amended, are U.S. market makers permitted to facilitate divestment from publicly traded securities of Chinese Military-Industrial Complex Companies (CMICs)?
OFAC's answer
Yes. U.S. market makers, and non-U.S. market makers who employ U.S. persons, are permitted to engage in activities that are necessary to effect divestiture during the during the 365-day periods in which divestment transactions are permitted or that are not otherwise prohibited under E.O. 13959, as amended, including the conversion of American depositary receipts (ADRs) of a CMIC into underlying securities of the CMIC on the foreign exchange where the underlying securities are listed. See [FAQ 865](https://ofac.treasury.gov/faqs/865)with respect to the permissibility of market intermediaries and other participants engaging in ancillary or intermediary activities that are necessary to effect divestiture of covered securities.