On January 2, 2025, the U.S. Department of Defense (DoD) updated the 1260H List of entities identified as “Chinese military companies” (CMC) operating in the United States, as required by section 1260H of the National Defense Authorization Act (NDAA) for Fiscal Year (FY) 2021 (Section 1260H), adding new entities and removing others. The updated 1260H
Communist Chinese Military Companies
DoD is Making its List, and Checking it Twice: DoD Updates 1260H Chinese Military Companies List
- Key takeaway #1: Contractors should continue monitoring DoD’s annual updates to the 1260H list.
- Key takeaway #2: Contractors should also be aware of any 1260H-listed entities in their supply chains and implement supply chain screening procedures to ensure compliance with the Entity Prohibition and Goods and Services Prohibition from Section
OFAC Issues Communist Chinese Military Companies General License 1A and Related Frequently Asked Questions
On January 27, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued General License 1A, “Authorizing Transactions Involving Securities of Certain Communist Chinese Military Companies,” (“GL 1A”) which amends and replaces General License 1 that had been initially issued on January 8, 2021. OFAC has also published related frequently asked…