The STOP CCP Act of 2025, introduced in the Senate, targets U.S. investments in Chinese companies tied to China’s defense, related materiel, or surveillance technology sectors. It prohibits United States persons from buying, selling, or otherwise transacting in publicly traded securities and related investment exposure of these Chinese entities, and it directs expansion of OFAC’s NS-CMIC List to include entities connected to the Chinese military-industrial complex. The bill also tightens sanctions by requiring that, when sanctions are imposed on a Chinese entity under any statute or executive order, the same sanctions be applied across all applicable authorities unless waived, with a national security waiver and congressional notification provisions, and it requires reporting on sanctions termination. Treasury would implement the expanded list and related regulations within 180 days of enactment. The bill’s sponsors argue the measures protect U.S. national security by cutting funding flows to potentially hostile Chinese entities.
Key Points
- 1Prohibition on securities investments: United States persons may not purchase or sell publicly traded securities (including derivatives or securities designed to provide exposure to those securities) issued by Chinese entities that operate in, or are owned/controlled by entities in, PRC defense or related materiel sectors or surveillance technology sectors, or by entities owned/controlled by such entities.
- 2Scope of prohibited activities: The prohibition covers execution, support, or servicing of these purchases, as well as any conspiracy to violate the prohibition or attempts to evade it.
- 3Expansion of the NS-CMIC List: Treasury, within 180 days, must expand OFAC’s Non-Specially Designated Nationals Chinese Military-Industrial Complex (NS-CMIC) List to include entities that support the Chinese military-industrial complex, their owners/controls, successors/spin-offs, and any entities providing financial services to those described.
- 4Regulatory timeline: The Treasury is required to prescribe the necessary regulations within 180 days of enactment.
- 5Closing sanctions loopholes: If sanctions are imposed on a Chinese entity under any statute or EO, the bill would generally require applying sanctions under all other applicable statutes/EOs unless waived by the President; it establishes a national security waiver with advance congressional notification and requires a post-waiver report, as well as a report within 20 days of any sanctions termination.