The Treasury Department's Office of Foreign Assets Control (OFAC) added China-based entities to the Non-SDN Menu-Based Sanctions List under the Protecting American Intellectual Property Act of 2022 (PAIPA). Section 2(b)(1)(A) blocks all property and interests in property of each listed entity and prohibits all transactions with each entity, except for imports of goods. Section 2(b)(1)(D) prohibits United States financial institutions from providing each entity with loans or credits totaling more than $10 million in any 12-month period, subject to the exception in that section. Section 2(b)(1)(H) prohibits foreign exchange transactions subject to United States jurisdiction in which any listed entity has an interest. Section 2(b)(1)(I) prohibits credit transfers or payments between financial institutions, or by, through or to any financial institution, when subject to United States jurisdiction and involving any listed entity's interest. Section 2(b)(1)(J) prohibits any United States person from investing in or purchasing significant amounts of equity or debt instruments of each listed entity.
OFAC also issued PAIPA General License 1, titled "Transactions Authorized Pursuant to the Cyber-Related Sanctions Regulations." OFAC issued PAIPA General License 2, titled "Authorizing the Wind Down of Transactions Involving Certain Entities Blocked on October 19, 2026."
OFAC added Beijing Qiji Chuangtan Phase I Venture Capital Center Limited Partnership, also known as Miracle Plus RMB Fund I. The listing identifies the partnership as linked to Qiji Chuangtan Beijing Investment Management Co Ltd. The partnership was established in June 2020 and has Unified Social Credit Code 91110108MA01QB5K5M.
OFAC added Beijing Qiji Chuangtan Phase II Venture Capital Center Limited Partnership, also known as Beijing Qijichuangtanerqi Chuangye Investment Center (Limited Partnership) and Miracle Plus RMB Fund II. The listing identifies the partnership as linked to Qiji Chuangtan Beijing Investment Management Co Ltd. The partnership was established in October 2022 and has Unified Social Credit Code 91110108MABQAUYK7G.
OFAC added Beijing Qiji Chuangtan Zhiyuan Enterprise Management Center Limited Partnership. The listing identifies the partnership as linked to Qiji Chuangtan Beijing Investment Management Co Ltd. The partnership was established on November 8, 2019, and has Unified Social Credit Code 91110108MA01NK6F9X.
OFAC added Qiji Chuangtan Beijing Investment Management Co Ltd, also known as Mengxi Chuangtan Beijing Investment Management Co Ltd and MiraclePlus. The company was established on March 6, 2019, and has Unified Social Credit Code 91110108MA01HHAHXF. Qiji Chuangtan Beijing Investment Management Co Ltd and the partnerships linked to that company share the listed address: No. 601, 6th Floor, No. 28 Chengfu Road, Haidian District, Beijing 100000, China.
OFAC added Shanghai Zhisuan Technology Co Ltd. The company was established on October 17, 2023, and has Unified Social Credit Code 91310104MAD3LXU92B. Shanghai Zhisuan Technology Co Ltd has the listed address: 44 Gongwei, Floor 1, Building 27, No. 487, Tianlin Road, Xuhui District, Shanghai 200000, China.
U.S. OFAC Adds Chinese Entities to PAIPA Sanctions List
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Summary
U.S. OFAC added several China-based entities to the PAIPA sanctions list, including Beijing Qiji Chuangtan-linked partnerships and Shanghai Zhisuan Technology Co Ltd. The move blocks property interests, restricts financial transactions, and prohibits investments in these firms. OFAC also issued two general licenses related to cyber sanctions and the wind down of transactions. The update comes amid growing AI + crypto news and developments in real-world assets (RWA) news.
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