US Executive Order - Chinese Military-Industrial Complex Companies (CMIC)

President Biden has issued an Executive Order (“EO”) 14032, revising US restrictions on publicly traded securities of specific Chinese companies. The new EO prohibits U.S. persons from buying or selling the publicly traded securities of listed companies operating in surveillance technology or defence sectors and comes into effect from 2 August 2021.

For further information, FAQs provided by the US Office of Foreign Asset Control (“OFAC”) can be found at: 

https://home.treasury.gov/policy-issues/financial-sanctions/faqs/topic/5671 

The amended EO applies to 59 Chinese companies. The companies are also included on OFAC’s new “Non-SDN Chinese Military-Industrial Complex Companies List” (“CMIC List”).

We can confirm that we apply the EO to all of our U.S. entities, funds and mandates. In advance of August 2, 2021 our pre-trade compliance systems were coded to ensure that securities and related derivatives subject to the EO are blocked from further purchases in respect of our U.S. entities, funds and mandates. We will continue to monitor any subsequent developments in relation to the amended EO and take necessary actions to come into compliance with those developments.

We can confirm that we hold one or more direct and indirect investments in the securities of those issuers in the [Schroders managed] funds found here.