CCMC vs CMIC Lists

On June 3rd, Treasury and the White House published major changes to Executive Order 13959, which imposed non-blocking sanctions on Communist Chinese Military Companies. Among the key changes included:

• Termination of the previous Executive Order

• Publication of a revised Executive Order which takes effect on 2 August 2021

• 8 new FAQs and 6 revised FAQs

• Elimination of restrictions on “close name match”

To understand the legal implications, we recommend that you read Steptoe’s post on this, but if you have questions about the data, see highlights below:

1. NS-CCMC list: 39 designees before termination

2. NS-CMIC list has 59 designees as of June 3rd

3. In the switch over between lists:

   • 10 designees were removed

   • 29 designees were migrated from NS-CMCC

   • 30 designees were added

The removed designees are:

1. CHINA STATE CONSTRUCTION GROUP CO., LTD.

2. CHINA CONSTRUCTION TECHNOLOGY CO. LTD. (CCTC)

3. CHINA THREE GORGES CORPORATION LIMITED

4. CHINA INTERNATIONAL ENGINEERING CONSULTING CORP. (CIECC)

5. CRRC CORP.

6. DAWNING INFORMATION INDUSTRY CO (SUGON)

7. CHINA NATIONAL CHEMICAL CORPORATION (CHEMCHINA)

8. CHINA NATIONAL CHEMICAL ENGINEERING GROUP CO., LTD. (CNCEC)

9. SINOCHEM GROUP CO LTD

10. CHINA SHIPBUILDING INDUSTRY CORPORATION (CSIC)

To see a full delta of the two lists, download the Excel file below.