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ARTICLE · 04 AUGUST 2020

OFAC Adds Chinese Entity To SDN List In Connection With Human Rights Abuses

Hogan Lovells Cadwalader
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OFAC designated a Chinese company and two individuals to the Specially Designated Nationals and Blocked Persons List.

ChinaGovernment, Public Sector
James Treanor
James Treanor
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OFAC designated the Xinjiang Production and Construction Corps ("XPCC") and two individuals to the Specially Designated Nationals and Blocked Persons List ("SDN List"). The designations were linked to human rights abuse in the Xinjiang Uyghur Autonomous Region ("XUAR"). In a general license, OFAC authorized certain "wind down and divestment" transactions and activities related to blocked subsidiaries of the XPCC through 12:01 a.m. EDT on September 30, 2020, which otherwise would be prohibited as a result of the sanctions imposed on the XPCC.

OFAC's designation of the XPCC was pursuant to Executive Order 13818, "Blocking the Property of Persons Involved in Serious Human Rights Abuse or Corruption," which implemented the Global Magnitsky Human Rights Accountability Act. As described in the U.S. Treasury Department's press release, the XPCC is a "paramilitary organization in the XUAR that is subordinate to the Chinese Communist Party (CCP)." The entity is also a large

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