30 Jul 2021
This document is important and requires your immediate attention
The U.S. Executive Order 14032 (“E.O.”) that was issued on 3 June 2021 prohibits transactions by U.S. Persons[i] with effect from 2 August 2021 in:
a) publicly traded securities of designated Chinese Military-Industrial Complex Companies ("CMIC") set out in the Non-SDN Chinese Military-Industrial Complex Companies List (“NS-CMIC List”) held by the Office of Foreign Assets Controls (“OFAC”); and
b) publicly traded securities that are derivative of the CMICs or are designed to provide investment exposure to the CMICs.
As a matter of group policy, we take all reasonable steps to comply with applicable U.S. OFAC regulations and E.O. requirements. Importantly, please note that:
1) Eastspring is not a U.S. Person; and
2) Eastspring range of mutual funds and unit trusts (“Eastspring funds”) are not U.S. Persons, nor are they eligible for investment by U.S. Persons.
Some Eastspring funds may hold and continue to engage in any transaction relating to any purchase or sale of publicly traded securities, or any publicly traded securities that are derivatives of such securities or are designed to provide investment exposure to such securities of any CMIC listed on the NS-CMIC List.
Any U.S. Person who may have inadvertently invested into an Eastspring fund must review its status and compliance obligations as a matter of priority and take all necessary steps to ensure that it shall remain in compliance of any applicable laws and regulations. This also applies to any appointed distributor of the Eastspring funds or financial intermediaries who may have inadvertently invested into an Eastspring fund on behalf a U.S. Person or allowed a U.S. Person to invest into an Eastspring fund.
In view of the fluidity of the situation as seen from the frequency of updates by OFAC, Eastspring will keep itself updated of the latest developments, and evaluate and fine-tune our response as appropriate. As the situation continues to evolve, and further guidance is issued, our response may be updated accordingly. Investors in the Eastspring funds are hereby reassured that such products will continue to be managed in the best interest of investors.
[i] The term “United States person” in the E.O. means any United States citizen, lawful permanent resident, entity organized under the laws of the United States or any jurisdiction within the United States (including foreign branches), or any person in the United States.
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