Migration of NS-CCMC List From Temporary Format to OFAC Standard List Format
Release date 04/30/2021
OFAC is migrating its existing Non-SDN Communist Chinese Military Companies (NS-CCMC) List from a temporary PDF and CSV file format to the standard OFAC list file format. The NS-CCMC list data will now be included in OFAC’s Non-SDN Consolidated Data Files for machine processing. Human-readable versions of the NS-CCMC list will now be available on a dedicated NS-CCMC landing page.
This is only an administrative, technical action. No new names have been added to the NS-CCMC list. OFAC has added the listing date, the effective date, and the divestment date to each list record to facilitate compliance with Executive Order 13959 .
Not for nothing, but about d*** time for both changes. While the absence of the NS-CCMC list from the Consolidated Sanctions List was an annoyance, the lack of the relevant dates for each listing was malpractice on OFAC’s part.
I do wonder, however, if OFAC has fully thought through the dates thing. If the NS-CCMC list gets updated the same day as the listing by DoD, that should be OK. But, so far, that hasn’t been the case – technically, the name listed by DoD has its own 60 day and 1 year countdowns on it, which is different than that for any data listed by OFAC in the NS-CCMC list.
Time to ask OFAC, I guess….