OFAC adds five China-based entities to sanctions list under intellectual property law
Five entities in Beijing and Shanghai were added to OFAC's Non-SDN Menu-Based Sanctions List under the Protecting American Intellectual Property Act, with blocking and banking measures.
The US Treasury's Office of Foreign Assets Control (OFAC) announced designations on 19 October 2026 under the Protecting American Intellectual Property Act of 2022 (PAIPA). Five entities located in Beijing and Shanghai, China, were added to OFAC's Non-SDN Menu-Based Sanctions List (NS-MBS List).
The entities are Beijing Qiji Chuangtan Phase I Venture Capital Center Limited Partnership (also known as Miracle Plus RMB Fund I), Beijing Qiji Chuangtan Phase II Venture Capital Center Limited Partnership (also known as Miracle Plus RMB Fund II and Beijing Qijichuangtanerqi Chuangye Investment Center (Limited Partnership)), Beijing Qiji Chuangtan Zhiyuan Enterprise Management Center Limited Partnership, Qiji Chuangtan Beijing Investment Management Co Ltd (also known as MiraclePlus and Mengxi Chuangtan Beijing Investment Management Co Ltd) and Shanghai Zhisuan Technology Co Ltd.
Each entry lists five measures under Section 2 of PAIPA: blocking of property, restrictions on loans from US financial institutions, foreign exchange, banking transactions, and a ban on US persons investing in or buying significant amounts of the entity's equity or debt.
OFAC also issued PAIPA General License 1, covering transactions authorized under the Cyber-Related Sanctions Regulations, and PAIPA General License 2, which authorizes the wind down of transactions involving certain entities blocked on 19 October 2026. OFAC's notice links to a US Department of State press release titled Imposing Sanctions to Protect Americans from Intellectual Property Theft, which could not be accessed for this story, so the reasons for the designations are not described here.
Why it matters to AML professionals
Not every OFAC measure appears on the SDN list, and entities on the NS-MBS list can still carry blocking and banking restrictions. AML professionals should confirm that their screening covers OFAC's non-SDN lists and that alerts are checked against the specific measures listed for each entry.
Red flags in this case
- Payments or investments involving a fund or company whose name or alias matches a newly listed entity
- Investment management firms linked to listed funds through shared names, addresses or registration codes
- Requests to move or restructure holdings in a newly listed entity shortly after the listing date
- Counterparties that use an English trade name that differs from the registered Chinese name
If this landed in your queue
- Confirm that your screening lists include OFAC's Non-SDN Menu-Based Sanctions List, not only the SDN list
- Screen customers, counterparties and holdings for the five names and their aliases, including transliterated forms
- Read the specific measures listed for any match and check which general licenses may apply
- Escalate true matches to the sanctions team and document the decision and any wind-down activity
Key terms
- Non-SDN Menu-Based Sanctions List (NS-MBS List)
- An OFAC list of persons subject to sanctions chosen from a menu of measures, rather than the full blocking that applies to the SDN list.
- General license
- OFAC permission that authorizes certain transactions that sanctions would otherwise prohibit, often for a limited time.
- Wind down
- Closing out existing dealings with a newly sanctioned party within the period and limits a license allows.
Interview angle
Why is screening against the SDN list alone not enough for US sanctions compliance?
Explain that OFAC keeps several lists, and that some, such as the NS-MBS List, impose specific measures that can include blocking. Say you would check list coverage, aliases and the exact measures before deciding how to handle a match.
Sources
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