Reminder: Restriction on Trading Securities and Related Derivatives of Some Chinese Companies - uncategorized
THE FOLLOWING INFORMATION IS FOR GENERAL INFORMATION PURPOSES ONLY AND MAY NOT BE CURRENT. IT IS NOT INTENDED TO CONSTITUTE LEGAL, INVESTMENT, OR OTHER PROFESSIONAL ADVICE AND SHOULD NOT BE RELIED ON OR TREATED AS A SUBSTITUTE FOR SPECIFIC ADVICE RELEVANT TO YOUR PARTICULAR CIRCUMSTANCES. THE INFORMATION BELOW ALSO DOES NOT CONSTITUTE AN OFFER TO SELL OR TRANSACT AND IS NEITHER A RECOMMENDATION NOR A SOLICITATION OF AN OFFER TO PURCHASE OR TRANSACT ANY INVESTMENT PRODUCT OR SERVICE.
On November 12, 2020, President Trump issued an Executive Order prohibiting U.S. persons from engaging in 「any transaction in publicly traded securities, or any securities that are derivative of, or are designed to provide investment exposure to such securities, of any Communist Chinese military company」 (「CCMC」). The list of CCMCs was subsequently expanded on December 3, 2020 and is subject to change at any time. It is your responsibility to assess your holdings and determine whether they have a direct, indirect, or derivative ownership interest in any of the companies designated as a CCMC.
As applied to companies designated as a CCMC on November 12, 2020, the Executive Order prohibits U.S. persons from opening new positions beginning 9:30 am eastern standard time on January 11, 2021. Open positions in those securities and derivatives held as of 9:30 am eastern standard time on January 11, 2021 should be closed on or before 11:59 p.m. eastern standard time on November 11, 2021 because you may not have the ability later to sell or transfer those securities and related derivatives.
The Executive Order provided that with respect to future designations, a similar prohibition would apply on the date that is 60 days after a company subsequently is determined by the U.S. government to be a CCMC. For those CCMCs, the Executive Order authorizes divestment-related transactions for a period of one year from the date that is 60 days after an entity subsequently is determined to be a CCMC.
For information purposes only, the tables below list the companies designated as CCMCs on November 12, 2020 and December 2, 2020. Please note, the list of CCMCS in the tables below may not be exhaustive and may not be current.You must exercise your own judgment for compliance with the transaction restrictions referred to in the Executive Order.
November 12, 2020:
| Company Name | Stock Type | Stock Code | Stock Name |
| CRRC Corp | A-share | 601766.SH | CRRC Corporation |
| H-share | 1766.HK | CRRC Corporation | |
| ADR | CRCCY.PK | CRRC Corp(ADR) | |
| China Communications Construction Company (CCCC) | A-share | 601800.SH | China Communications Construction |
| H-share | 1800.HK | China Communications Construction | |
| ADR | CCCGY.PK | CHINA COMM CONSTR(ADR) | |
| China National Chemical Engineering Group Co. (CNCEC) | A-share | 601117.SH | China National Chemical Engineering |
| China Nuclear Engineering & Construction Corporation (CNECC) | A-share | 601611.SH | China Nuclear Engineering Corporation |
| China Spacesat Co., Ltd. | A-share | 600118.SH | China Spacesat |
| China State Construction Group Co., Ltd. | H-share | 3311.HK | China State Construction International |
| ADR | CCOHY.PK | CHINA STATE CONSTR(ADR) | |
| China Railway Construction Corporation (CRCC) | A-share | 601186.SH | China Railway Construction Corporation |
| H-share | 1186.HK | China Railway Construction Corporation | |
| ADR | CWYCY.PK | CHINA RAILWAY CONS(ADR) | |
| Dawning Information Industry Co (Sugon) | A-share | 603019.SH | Dawning Information Industry |
| Hangzhou Hikvision Digital Technology Co Ltd (Hikvision) | A-share | 002415.ZK | Hangzhou Hikvision Digital Technology |
| Panda Electronics Group | A-Share | 600775.SH | Nanjing Panda Electronics |
| H-Share | 00553.HK | Nanjing Panda Electronics | |
| China United Network Communications Group Co Ltd | A-Share | 600050.SH | China United Network Communications |
December 2, 2020:
Company Name | Stock Type | Stock Code | Stock Name |
Semiconductor Manufacturing International Corp. | A-share | 688981.SH | Semiconductor Manufacturing International Corp |
H-share | 0981.HK | Semiconductor Manufacturing International Corp | |
ADR | SMICY.PK | Semiconductor Manufacturing International Corp (ADR) | |
China National Offshore Oil Corp. (CNOOC) | H-share | 00883.HK | CNOOC Limited |
ADR | CEO | Cnooc Limited (ADR) |
Please refer to the links below for details on the Executive Order and the list of CCMCs:
The Executive Order:
https://www.whitehouse.gov/presidential-actions/executive-order-addressing-threat-securities-investments-finance-communist-chinese-military-companies/
U.S. Department of Defense Release on December 3, 2020: https://www.defense.gov/Newsroom/Releases/Release/Article/2434513/dod-releases-list-of-additional-companies-in-accordance-with-section-1237-of-fy/
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