Invesco’s policy is to fully comply with all applicable sanctions globally, including but not limited to sanctions issued by the US Treasury Department’s Office of Foreign Assets Control (“OFAC”), the United Nations (“UN”) and the European Union (“EU”). We are aware of Executive Order 13959 (“EO 13959”) relating to Communist Chinese Military Companies (“CCMCs”) and associated guidance issued by OFAC in the form of FAQs and verbal guidance to industry trade associations.
Our policy is to comply with EO 13959 and OFAC guidance, in particular relating to restrictions on trading in securities prohibited by the Executive Order, effective January 11, 2021 and the associated divestment period.
For US registered funds and portfolios and other US commingled products, Invesco’s policy is to prohibit the purchase of any securities of those entities initially sanctioned listed under EO 13959 from January 11, 2021 (with securities of subsequently sanctioned entities commencing from and after the relevant such future date for CCMC securities subsequently listed by OFAC).
For non-US registered funds and portfolios determined to have a sufficient US nexus (e.g., shareholders identified as US persons), we are adopting a similar approach.
Our approach to compliance with EO 13959 includes our intention to divest such holdings as per the November 11, 2021 divestiture period (or any such future date as determined by OFAC).