New episode of Mr, Watchlist’s DesigNation is now out – Last Minute Reprieve. It’s about the Chinese Military Companies General License issued late Friday, what it does, why it was issued and how OFAC might clean up the mess they made when they issued FAQ 864.
Oh, and yes… that there’s a need to fix the NS-CCMC List already. At least some of the listed securities and issuers should be removed because they actually correspond to subsidiaries, not companies designated already by Defense or Treasury.
And, yes, after I recorded the episode and realized that OFAC needed to fix the List, I emailed them. Even if the “fix” is to designate the subsidiaries, the List would still need to be updated such that the subsidiaries are listed by themselves and not erroneously as part of the parent company.
I’ve actually only researched one of the firms (China Mobile Limited), and it really bugs me that they very first one I checked had this problem. I would not be surprised to find that, in the Administration’s zeal, they overreached on all the telecom firms, if not others…