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Don’t take OFAC’s NS-CCMC as gospel

A word to the wise: OFAC’s Non-SDN Communist Chinese Military Companies List (NS-CCMC) is not 100% accurate – and in a particularly unpleasant way.

Simply put, don’t trust the Issuer data – verify it for yourselves. While I haven’t done a ton of verification, I can tell you that China Mobile Limited appears to be a subsidiary of the company listed by the Department of Defense, and is not merely an issuer name. While perhaps one could be suspicious, China Mobile Limited’s website says:

China Mobile Limited (the “Company”, and together with its subsidiaries, the “Group”) was incorporated in Hong Kong on 3 September 1997. The Company was listed on the New York Stock Exchange (“NYSE”) and The Stock Exchange of Hong Kong Limited (“HKEX” or the “Stock Exchange”) on 22 October 1997 and 23 October 1997, respectively. The Company was admitted as a constituent stock of the Hang Seng Index in Hong Kong on 27 January 1998.


The Company’s ultimate controlling shareholder is China Mobile Communications Group Co., Ltd. (formerly known as China Mobile Communications Corporation, “CMCC”), which, as of 31 December 2019, indirectly held approximately 72.72% of the total number of issued shares of the Company. The remaining approximately 27.28% was held by public investors.

So, that seems to imply that China Mobile Limited, and its US and Hong Kong securities identifiers, shouldn’t appear in the NS-CCMC List, since neither Defense or Treasury has designated it.

And you have to wonder, what else is inaccurate in the list, perhaps driven by FAQ 864 (which I’ve already devoted way too much bandwidth to)?


China Mobile Limited Overview page

Categories: Non-SDN Communist Chinese Military Companies (NS-CCMC) List updates OFAC Updates


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