Skip to content

Menu

LexBlog, Inc. logo
NetworkSub-MenuBrowse by SubjectBrowse by PublisherJoin the NetworkGet StartedSubscribeSupport
Contact Us
Search
Close

OFAC Adds Chinese Tech Company CEIEC to SDN List, Issues General License 38 Authorizing Wind-Down Activities

By Cherie Tremaine, Peter Jeydel & Ed Krauland on December 3, 2020
Email this postTweet this postLike this postShare this post on LinkedIn

On November 30, 2020, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced the addition of Chinese company CEIEC to its list of Specially Designated Nationals and Blocked Persons (SDN List), pursuant to Executive Order 13692, for “its role in undermining democracy in Venezuela.”  OFAC also issued General License 38 authorizing certain wind-down activities with CEIEC, as well as an FAQ regarding the designation and general license.

According to Treasury, CEIEC, also known as China National Electronic Import-Export Company, has over 200 offices and subsidiaries worldwide.  CEIEC explains on its website, https://www.ceiec.com/About, that it is a “close partner of many foreign government[s], military and security department[s], to help them fulfill their mission of securing citizen’s confidence to health, safety, economic growth and public governance.”

In the press release announcing CEIEC’s addition to the SDN List, Treasury explained that the designation is due to the company’s involvement in “actions or policies that undermine democratic processes or institutions” in Venezuela.  For example, Treasury stated that CEIEC provided “software, training, and technical expertise to Venezuela[n] government entities, which was then used against the people of Venezuela.”

Concurrent with CEIEC’s designation, OFAC issued General License 38, which authorizes until 12:01 a.m. eastern standard time on January 14, 2021, certain transactions and activities by US persons that are ordinarily incident and necessary to the wind down of transactions and activities involving CEIEC or its subsidiaries.  In addition, and of significance to non-US persons, the FAQ issued by OFAC notes that from a “secondary sanctions” perspective, non-US persons should be mindful of the wind-down period set forth in the General License.  This FAQ states in part that “[e]ntering into new business involving the Blocked CEIEC Entities will not be considered wind-down activity.  Non-U.S. persons unable to wind down activities with the Blocked CEIEC Entities before 12:01 a.m. eastern standard time, January 14, 2021, may seek guidance from OFAC.”

Photo of Peter Jeydel Peter Jeydel

Peter Jeydel‘s practice focuses on US export controls and economic sanctions, including the Commerce Department’s Export Administration Regulations (EAR), the State Department’s International Traffic in Arms Regulations (ITAR), and sanctions regulations administered by the Treasury Department’s Office of Foreign Assets Control (OFAC)…

Peter Jeydel‘s practice focuses on US export controls and economic sanctions, including the Commerce Department’s Export Administration Regulations (EAR), the State Department’s International Traffic in Arms Regulations (ITAR), and sanctions regulations administered by the Treasury Department’s Office of Foreign Assets Control (OFAC) and the State Department. His practice spans all aspects of these regimes, including counseling, compliance, transactional advice, licensing and opinions, disclosures, and enforcement actions. He has also represented companies and individuals seeking de-listing from OFAC’s sanctions list. In addition, Pete has assisted clients in anti-corruption matters, including under the US Foreign Corrupt Practices Act (FCPA), and has experience handling reviews and investigations by the Committee on Foreign Investment in the United States (CFIUS).

Read Pete’s full bio.

Read more about Peter JeydelEmail
Show more Show less
Photo of Ed Krauland Ed Krauland

Edward J. Krauland focuses on export controls/economic sanctions. Ed’s extensive experience includes representing clients on matters involving US and multilateral economic sanctions, defense and nuclear export controls, dual-use export controls under the EAR, anti-boycott compliance, internal investigations and enforcement work, and review of…

Edward J. Krauland focuses on export controls/economic sanctions. Ed’s extensive experience includes representing clients on matters involving US and multilateral economic sanctions, defense and nuclear export controls, dual-use export controls under the EAR, anti-boycott compliance, internal investigations and enforcement work, and review of government procurement regulations in the cross-border context. His practice spans all aspects of these laws, including counseling, compliance work, transactional advice, licensing and opinion work, internal reviews, disclosures, and enforcement actions. He has served as co-chair of the International Trade Committee of the ABA Section of International Law and Practice. He is former Chairman of an ABA-wide Task Force on Gatekeeper Regulation (anti-money laundering compliance), and senior adviser to the ABA Section of International Law and Practice’s anti-money laundering committee.

Read Ed’s full bio.

Read more about Ed KraulandEmail
Show more Show less
  • Posted in:
    Banking, Finance and Securities
  • Blog:
    International Compliance Blog
  • Organization:
    Steptoe LLP

Call us at 1-800-913-0988 or email sales@lexblog.com.

Facebook LinkedIn Twitter RSS
  • About LexBlog
  • The Field We Built
  • Our Beliefs
  • Our Team
  • Contact LexBlog
  • Disclaimer
  • Editorial Policy
  • Terms of Service
  • Get Started
  • Publishing Solutions
  • Compass
  • Submit a Request
  • Support Center
  • System Status
Copyright © 2026, LexBlog, Inc. All Rights Reserved.
Law blog design & platform by LexBlog LexBlog Logo