On 31 July, OFAC announced the issue of General License 2 “Authorizing Certain Wind Down and Divestment Transactions and Activities Related to Blocked Subsidiaries of the Xinjiang Production and Construction Corps (XPCC)”, as well as a new FAQ 835 explaining the purpose and use of the General License.  The General License runs to 30 September and the FAQ warns that, after the expiration of the general authorisation it contains, US persons will be prohibited from engaging in or facilitating transactions with Blocked XPCC Subsidiaries unless exempt or authorised by OFAC.

Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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