On November 12, 2020, President Trump issued Executive Order 13959,
entitled "Addressing the Threat from Securities Investments that Finance
Communist Chinese Military Companies" (the "E.O."). The E.O.
prohibits U.S. persons from transacting in publicly traded securities of
any "Communist Chinese military company" ("CCMC") (such securities,
"Sanctioned CCMC Securities") identified on a list maintained by the
Department of Defense from and after January 11, 2021 (or, in the case of
entities that are subsequently listed as CCMCs, 60 days from such listing),
provided that U.S. persons may continue to hold Sanctioned CCMC Securities
and may divest by selling them to non-U.S. persons at any time until
November 12, 2021 (or one year from listing, in the case of subsequently
listed Sanctioned CCMC Securities).
We are closely monitoring developments relating to the E.O., and in
particular, we are taking the following steps, among others, to meet the
requirements of the E.O.:
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We have complied, and will continue to comply, with the EO;
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We have not purchased and will not purchase for value any Sanctioned
CCMC Securities on or after the applicable effective date of the
restrictions;
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We will take all steps to ensure that funds which are currently held or
eligible for purchase by US persons remain eligible under the EO;
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If additional CCMCs become subject to the restrictions under the E.O.,
to the extent required by the E.O., we will not purchase for value any
of these additional Sanctioned CCMC Securities on or after the
effective date of the restrictions applicable to such Sanctioned CCMC
Securities and will divest Sanctioned CCMC Securities within the
deadlines imposed under the E.O;
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We are working closely with leading industry groups, including SIFMA
and ICI, to monitor and respond to developments in real time, and are
working with external counsel where appropriate;
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We are reviewing relevant government communications, including guidance
and other communications from the Office of Foreign Assets Control (" OFAC") of the U.S. Department of Treasury, and adapting our
compliance efforts accordingly; and
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We maintain a robust Sanctions Compliance Program ("SCP")
consistent with OFAC guidance, which includes, among other things, the
application of customary blocking, screening and monitoring practices,
which we are deploying in response to the E.O.
We recognize the unique challenges resulting from the issuance and
implementation of the E.O., and will continue to work closely with
stakeholders and external counsel where appropriate to identify and take
necessary actions to meet the requirements of the E.O.