On November 12, 2020, U.S. President Donald Trump issued Executive Order 13959 (the "Executive Order"), which prohibits U.S. Persons from purchasing "publicly traded securities" of 35 Chinese companies identified as Communist Chinese Military Companies ("CCMCs") or engaging in any transaction in "any securities that are derivative of, or are designed to provide investment exposure to" prohibited CCMC securities. Under the Executive Order, U.S. Persons cannot make purchases of CCMC securities effective January 11, 2021 and have until November 11, 2021 to divest from these securities.
On December 28, 2020, the U.S. Treasury Department's Office of Foreign Assets Control ("OFAC") issued requirements regarding restrictions and processes in connection with the Executive Order.
OFAC's guidance restricts U.S. Persons from investing in securities in any foreign or U.S. fund, including registered funds that hold publicly traded securities of a CCMC. OFAC also confirmed that the prohibitions on CCMC securities do not apply to securities of subsidiaries unless and until the subsidiary is listed by OFAC, in which case the prohibitions will take effect 60 days after the subsidiary is listed by OFAC.
Aberdeen Standard Investments ("ASI")
To ensure compliance with requirements of the Executive Order, Aberdeen Standard Investments ("ASI") can confirm that none of our U.S.-domiciled funds, including our U.S. registered funds*, hold any sanctioned CCMC securities or are in the process of divesting from these positions in accordance with OFAC's requirements and timelines. In the limited instances where divestment is required under the Executive Order, the exposure to CCMC securities does not represent a significant portion of the portfolio (no more than 3%).
ASI's sanctions compliance framework has been amended to comply with the requirements of the Executive Order via our screening processes, pre-and post-trade guidelines, and oversight procedures in connection with investment and client activity. ASI will continue to monitor and ensure the procedures and controls for our sanctions compliance program addresses updates to the CCMC list and additional actions required in connection with the Executive Order.
If you have any questions or further information is required, please contact ASI's Investor Relations team or your designated Business Development Manager or Client Service Associate.
* Aberdeen Standard Investments U.S. Registered Funds
ASI Mutual Funds
ASI Closed-End Funds
Series of Aberdeen Funds Trust
Aberdeen Emerging Markets Equity Income Fund, Inc. (AEF)
Aberdeen Japan Equity Fund, Inc. (JEQ)
Series of Aberdeen Investment Funds Trust
Aberdeen Global Dynamic Dividend Fund (AGD)
Aberdeen Asia-Pacific Income Fund, Inc. (FAX)
Aberdeen Total Dynamic Dividend Fund (AOD)
Aberdeen Global Income Fund, Inc. (FCO)
The India Fund, Inc. (IFN)
Aberdeen Income Credit Strategies Fund (ACP)
Aberdeen Australia Equity Fund, Inc. (IAF)
Aberdeen Global Premier Properties Fund (AWP)
Aberdeen Standard Global Infrastructure Income Fun (ASGI)
Aberdeen Standard Investments 1900 Market Street, Suite 200, Philadelphia, PA 19103
In the United States, Aberdeen Standard Investments ("ASI") is the marketing name for the following affiliated, registered investment advisers: Aberdeen Standard Investments Inc., Aberdeen Asset Managers Ltd., Aberdeen Standard Investments Australia Ltd., Aberdeen Standard Investments (Asia) Ltd., Aberdeen Capital Management, LLC, Aberdeen Standard Investments ETFs Advisors LLC and Aberdeen Standard Alternative Funds Limited. Member of the Standard Life Aberdeen Group of Companies.