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Compliance with US Executive Order 13959


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.:

  • We have complied, and will continue to comply, with the EO;
  • We have not purchased and will not purchase for value any Sanctioned CCMC Securities on or after the applicable effective date of the restrictions;
  • 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;
  • 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;
  • 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;
  • 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
  • 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.

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