Q&A

Q&A: MSCI’STREATMENT OF
SECURITIES IMPACTED
BY U.S. EXECUTIVE
ORDER 13959, AS
AMENDED BYEXECUTIVE ORDER
14032
December 2021

December 2021

Q&A: MSCI’S TREATMENT OF SECURITIES IMPACTED BY U.S. EXECUTIVE ORDER 13959, AS
AMENDED BY EXECUTIVE ORDER 14032 | DECEMBER 2021

Contents

General Questions

4

What has been MSCI’s treatment of securities impacted by U.S.
Executive Order 13959, including as amended by Executive Order 14032
on June 3, 2021?
4
What changed when Executive Order 13959 was amended by Executive
Order 14032?
4
How does MSCI treat securities impacted by the amended Order?

4

Which securities are excluded from the MSCI ACWI Indexes?

5

What treatment does MSCI apply to securities which had been but are
no longer impacted under the amended Order?
5
Which securities previously deleted from the MSCI ACWI Indexes are nolonger impacted by the amended Order?
6
Are MSCI China All Shares Indexes subject to the same treatment as the
MSCI ACWI Indexes?
6
Which securities are excluded from the MSCI China All Shares Indexes?
6
Which securities previously deleted from the MSCI China All Shares
Indexes are no longer impacted by the amended Order?

7

Are securities impacted by the amended Order excluded from the MSCI
Factor, ESG, Thematic and Capped Indexes?
8
Does MSCI apply the same treatment in MSCI Factor, ESG, Thematicand Capped Indexes for securities which had been but are no longer
impacted under the amended Order?

8

Are securities impacted by the amended Order excluded from MSCI’s
custom indexes?
8
Is the same treatment applied to the MSCI China A and China A RMB
Indexes?

8

Is same treatment applied to the MSCI China A Onshore Indexes?

9

Has MSCI separately made available a list of impacted indexes?

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Q&A: MSCI’S TREATMENT OF SECURITIES IMPACTED BY U.S. EXECUTIVE ORDER 13959, AS
AMENDED BY EXECUTIVE ORDER 14032 | DECEMBER 2021

What will MSCI do should there be further updates to the securities
impacted by Executive Order 13959, as amended by Executive Order
14032?

9

Did MSCI seek feedback from clients with regards to Executive Order
13959?

9

Does MSCI provide indexes that include securities excluded from the
MSCI GIMI due to Executive Order 13959, as amended by Executive
Order 14032?
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Q&A: MSCI’S TREATMENT OF SECURITIES IMPACTED BY U.S. EXECUTIVE ORDER 13959, AS
AMENDED BY EXECUTIVE ORDER 14032 | DECEMBER 2021

General Questions
What has been MSCI’s treatment of securities impacted by U.S.
Executive Order 13959, including as amended by Executive
Order 14032 on June 3, 2021?
As of the close of January 5, January 8, January 26, 2021 and July 26, 2021, MSCI
deleted the securities impacted by U.S. Executive Order 13959, including as it wasamended by Executive Order 14032, from the MSCI Global Investable Market Indexes(GIMI), which covers the MSCI ACWI Indexes and MSCI China All Shares Indexes, andfrom relevant non-market capitalization weighted indexes and custom indexes. On
December 21, 2021, MSCI announced that it will delete as of the close of February 9,2022 additional impacted securities that were included in OFAC’s announcement on
December 16, 2021.

What changed when Executive Order 13959 was amended by
Executive Order 14032?
Executive Order 13959 was amended by Executive Order 14032 on June 3, 2021
(collectively, the amended Order). At the time, the Office of Foreign Assets Control(OFAC) published an updated Non-Specifically Designated Nationals (SDN) List ofcompanies and related security tickers, described by OFAC as the Non-SDN Chinese
Military-Industrial Complex Companies List (NS-CMIC List), which led to MSCI
making changes to its indexes as described herein. See the amended Order and
OFAC’s Frequently Asked Questions for additional information.

How does MSCI treat securities impacted by the amended
Order?
MSCI deletes securities impacted by the amended Order. Specifically, MSCI deleted
securities impacted by the Order from the MSCI GIMI and relevant non-market
capitalization weighted indexes and custom indexes, as of the close of January 5,
January 8, and January 26, 2021.
On July 8, 2021, MSCI announced that it would delete the securities included in
OFAC’s updated NS-CMIC List from the MSCI GIMI and relevant non-market
capitalization weighted indexes and custom indexes, as of the close of July 26, 2021
(effective July 27, 2021) in one step.
On December 21, 2021, MSCI announced that it will delete the additional securities
included in OFAC’s update of the NS-CMIC List announced on December 16, 2021
from the MSCI GIMI and relevant non-market capitalization weighted indexes and© 2021 MSCI Inc. All rights reserved. Please refer to the disclaimer at the end of this document.

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Q&A: MSCI’S TREATMENT OF SECURITIES IMPACTED BY U.S. EXECUTIVE ORDER 13959, AS
AMENDED BY EXECUTIVE ORDER 14032 | DECEMBER 2021

custom indexes, as of the close of February 9, 2022 (effective February 10, 2022) in
one step.

Which securities are excluded from the MSCI ACWI Indexes?
MSCI deletes and excludes from the MSCI ACWI Indexes the following securities thatare named in OFAC’s NS-CMIC List, each prior to the applicable effective date under
the amended Order.

MSCI Security
Code35946.0435946.01
60088.03
60088.02
36812.02
64314.02
29098.01
22535.01
27867.01
23733.01
24149.01
28680.02
62650.0261854.02
62140.02
30206.0262339.0263563.02
77520.02

RIC

Security Name

601800.SH
1800.HK
601186.SH
1186.HK
600118.SH
002415.ZK
0981.HK
0941.HK0728.HK0762.HK
0883.HK
600879.SH
600862.SH
002179.ZK
600760.SH
000768.ZK
600372.SH
601989.SH
603019.SH

CHINA COMMU CON A (HK-C)
CHINA COMMUNIC CONST H
CHINA RAIL CONST A(HK-C)
CHINA RAILWAY CONST H
CHINA SPACESAT A (HK-C)
HANGZHOU HIKVIS A (HK-C)
SMIC
CHINA MOBILECHINA TELECOM CORP H
CHINA UNICOM
CNOOC
AEROSPACE TIMES A (HK-C)
AVIC AVIATION HI A(HK-C)
AVIC JONHON OPTR A(HK-C)
AVIC SHENYANG A (HK-C)
AVIC XI AN A (HK-C)
CHINA AVIONICS A (HK-C)
CHINA SHIPB IND A (HK-C)DAWNING INFO A (HK-C)

Deletion Date(as of close)
1/5/2021
1/5/2021
1/5/2021
1/5/2021
1/5/2021
1/5/2021
1/5/2021
1/8/2021
1/8/2021
1/8/2021
1/26/2021
7/26/2021
7/26/2021
7/26/2021
7/26/2021
7/26/2021
7/26/2021
7/26/2021
2/9/2022

What treatment does MSCI apply to securities which had been
but are no longer impacted under the amended Order?
Securities which had been but since have ceased to be impacted under the amended
Order become eligible for potential inclusion in the MSCI GIMI starting from the next
applicable Index Review.
Any addition of such securities in the MSCI GIMI as part of the Index Review issubject to the securities meeting all necessary requirements for new companies, as
described in the GIMI Methodology.

© 2021 MSCI Inc. All rights reserved. Please refer to the disclaimer at the end of this document.

MSCI.COM | Page 5 of 13

Q&A: MSCI’S TREATMENT OF SECURITIES IMPACTED BY U.S. EXECUTIVE ORDER 13959, AS
AMENDED BY EXECUTIVE ORDER 14032 | DECEMBER 2021

Which securities previously deleted from the MSCI ACWI
Indexes are no longer impacted by the amended Order?
MSCI Security
Code

RIC

Security Name

28348.02
61687.03
61687.02

600050.SH
601766.SH
1766.HKCHINA UTD NETWK A (HK-C)
CRRC CORP A (HK-C)
CRRC CORP H

Prior Deletion
Date (as ofclose)
1/5/2021
1/5/2021
1/5/2021

Are MSCI China All Shares Indexes subject to the same
treatment as the MSCI ACWI Indexes?
Yes. MSCI deleted securities impacted by the Order from the MSCI China All Shares
Indexes, as of the close of January 5, January 8, and January 26, 2021. MSCI deleted
the securities included in OFAC’s NS-CMIC List from the MSCI China All Shares
Indexes as of the close of July 26, 2021 (effective July 27, 2021) in one step and will
delete the securities included in OFAC’s update of the NS-CMIC List announced on
December 16, 2021 from the MSCI China All Shares Indexes as of the close of
February 9, 2022 (effective February 10, 2022) in one step.
In addition, securities which had been but have ceased to be impacted under theamended Order become eligible for potential inclusion in the MSCI China All Shares
Indexes starting from the next applicable Index Review. Any addition of suchsecurities in the MSCI China All Shares Indexes as part of the Index Review is subject
to the securities meeting all necessary requirements for new companies, as
described in the GIMI Methodology.

Which securities are excluded from the MSCI China All Shares
Indexes?
MSCI deletes and excludes the following securities from the MSCI China All Shares
Indexes that are part of OFAC’s NS-CMIC List, prior to the applicable effective dates.

MSCI Security
Code35946.0335946.01
60088.01
60088.02
36812.01
64314.01

RIC Code

Security Name

601800.SS
1800.HK
601186.SS
1186.HK
600118.SS
002415.SZ

CHINA COMMUNIC CONST A
CHINA COMMUNIC CONST H
CHINA RAILWAY CONST A
CHINA RAILWAY CONST H
CHINA SPACESAT A
HANGZHOU HIKVISION DIG A© 2021 MSCI Inc. All rights reserved. Please refer to the disclaimer at the end of this document.

Deletion Date(as of close)
1/5/2021
1/5/2021
1/5/2021
1/5/2021
1/5/2021
1/5/2021

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Q&A: MSCI’S TREATMENT OF SECURITIES IMPACTED BY U.S. EXECUTIVE ORDER 13959, AS
AMENDED BY EXECUTIVE ORDER 14032 | DECEMBER 2021

34563.02
29098.01
29098.03
22535.01
27867.01
23733.01
24149.01
28680.01
36809.01
96793.01
62650.01
61789.01
61854.01
62140.01
30206.01
97327.01
62339.01
61986.0163563.01
62385.01
78349.01
62229.01
36805.01
16904.01
97646.01
77520.01
97724.01
97257.01

600775.SS
0981.HK
688981.SS
0941.HK0728.HK0762.HK
0883.HK
600879.SS
600501.SS
601606.SS
600862.SS
600765.SS
002179.SZ
600760.SS
000768.SZ
300474.SZ
600372.SS
600482.SS
601989.SS
002189.SZ
603678.SS
002025.SZ
600316.SS
003009.SZ
300114.SZ
603019.SS
300603.SZ
300188.SZ

NANJING PANDA ELECTRS A
SMICSMIC ACHINA MOBILECHINA TELECOM CORP H
CHINA UNICOM
CNOOC
AEROSPACE TIMES ELECTR AAEROSUN CORP A
ANHUI GREATWALL A
AVIC AVIATION HIGH A
AVIC HEAVY MACHINERY A
AVIC JONHON OPTRONIC A
AVIC SHENYANG AIRCRAFT A
AVIC XI AN AIRCRAFT A
CHANGSHA JINGJIA ACHINA AVIONICS SYSTEMS ACHINA SHIPBUILDING A
CHINA SHIPBUILDING IND A
COSTAR GROUP CO A
FUJIAN TORCH ELECTRON AGUIZHOU SPACE APPL AJIANGXI HONGDU AVIAT A
SHAANXI ZHONGTIAN AZHONGHANG ELECT ADAWNING INFORMATION ALEON TECHNOLOGY CO A
XIAMEN MEIYA PICO INFO

1/5/2021
1/5/2021
1/5/2021
1/8/2021
1/8/2021
1/8/2021
1/26/2021
7/26/2021
7/26/2021
7/26/2021
7/26/2021
7/26/2021
7/26/2021
7/26/2021
7/26/2021
7/26/2021
7/26/2021
7/26/2021
7/26/2021
7/26/2021
7/26/2021
7/26/2021
7/26/2021
7/26/2021
7/26/2021
2/9/2022
2/9/2022
2/9/2022

Which securities previously deleted from the MSCI China All
Shares Indexes are no longer impacted by the amended Order?
MSCI Security
Code28348.01
61687.01
61687.02
99078.01

RIC Code

Security Name

600050.SS
601766.SS
1766.HK
688012.SS

CHINA UTD NETWK COMMU A
CRRC CORP A
CRRC CORP H
ADV MICRO FABRICATION A© 2021 MSCI Inc. All rights reserved. Please refer to the disclaimer at the end of this document.

Deletion Date(as of close)
1/5/2021
1/5/2021
1/5/2021
3/12/2021

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Q&A: MSCI’S TREATMENT OF SECURITIES IMPACTED BY U.S. EXECUTIVE ORDER 13959, AS
AMENDED BY EXECUTIVE ORDER 14032 | DECEMBER 2021

Are securities impacted by the amended Order excluded from
the MSCI Factor, ESG, Thematic and Capped Indexes?
Yes. The securities impacted by Executive Order 13959, as amended by Executive
Order 14032, are excluded from the MSCI Factor, ESG, Thematic and Capped Indexes
that have the MSCI ACWI Indexes or the MSCI China All Shares Indexes as underlying
or parent index, applying the same timeframes for deletion and exclusion.

Does MSCI apply the same treatment in MSCI Factor, ESG,
Thematic and Capped Indexes for securities which had been
but are no longer impacted under the amended Order?
Securities which had been but are no longer impacted under the amended Orderbecome eligible for potential inclusion in the MSCI Factor, ESG, Thematic andCapped Indexes that have the MSCI ACWI Indexes or the MSCI China All Shares
Indexes as underlying or parent index, subject to the relevant index inclusion
methodology and starting from the next applicable Quarterly Index Review.

Are securities impacted by the amended Order excluded from
MSCI’s custom indexes?
Yes. The securities impacted by the amended Order generally are excluded from thecustom indexes that have the MSCI ACWI Indexes or the MSCI China All Shares
Indexes as underlying or parent index.
If another treatment is requested, parallel versions of current custom indexes will
also be available upon request. MSCI reminds users of its indexes for any purpose,including both indexed and active management, that they are responsible for
ensuring compliance with all applicable sanctions and any other rules, regulations,prohibitions, laws and other restrictions applicable to their portfolios, trading andother investment activity.

Is the same treatment applied to the MSCI China A and China A
RMB Indexes?
Yes. The securities impacted by the amended Order are excluded from the MSCI
China A and China A RMB Indexes.
Similarly, securities which had been but have ceased to be impacted under theamended Order become eligible for potential inclusion in the MSCI China A and China
A RMB Indexes starting from the next applicable Quarterly Index Review.

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Q&A: MSCI’S TREATMENT OF SECURITIES IMPACTED BY U.S. EXECUTIVE ORDER 13959, AS
AMENDED BY EXECUTIVE ORDER 14032 | DECEMBER 2021

Is same treatment applied to the MSCI China A Onshore
Indexes?
No. MSCI will not delete securities from the MSCI China A Onshore Indexes inconnection with the amended Order. MSCI reminds users of its indexes for any
purpose, including both indexed and active management, that they are responsible
for ensuring compliance with all applicable sanctions and any other rules,
regulations, prohibitions, laws and other restrictions applicable to their portfolios,
trading and other investment activity.

Has MSCI separately made available a list of impacted
indexes?
Yes. The list of impacted MSCI Indexes is available on: https://www.msci.com/indexconsultations

What will MSCI do should there be further updates to thesecurities impacted by Executive Order 13959, as amended by
Executive Order 14032?
Any updates to the above referenced list of securities, made through acommunication released by OFAC will also result in any added securities being
deleted from the MSCI GIMI, from related non-market capitalization weighted indexes
and from relevant custom indexes. MSCI would issue a separate announcement
detailing the treatment related to any such updates.

Did MSCI seek feedback from clients with regards to Executive
Order 13959?
MSCI extended a broad outreach and collected feedback from market participants
globally from November 20 to December 4, 2020 in relation to the Order.
More than 100 U.S. and non-U.S. market participants provided feedback andindicated generally that the Order has a significant impact on the investment
processes of global investors. Consultation participants highlighted that the Orderchallenges the investability of the impacted securities from the perspective of
institutional investors.

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Q&A: MSCI’S TREATMENT OF SECURITIES IMPACTED BY U.S. EXECUTIVE ORDER 13959, AS
AMENDED BY EXECUTIVE ORDER 14032 | DECEMBER 2021

Does MSCI provide indexes that include securities excluded
from the MSCI GIMI due to Executive Order 13959, as amended
by Executive Order 14032?
MSCI publishes global, regional and country indexes (e.g., ACWI, Emerging Markets,
China) that continue to retain the securities deleted from the MSCI GIMI due to theOrder. Parallel versions of custom indexes are also available upon request.
MSCI reminds users of its indexes for any purpose, including both indexed and active
management, that they are responsible for ensuring compliance with all applicablesanctions and any other rules, regulations, prohibitions, laws and other restrictions
applicable to their portfolios, trading and other investment activity.

© 2021 MSCI Inc. All rights reserved. Please refer to the disclaimer at the end of this document.

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Q&A: MSCI’S TREATMENT OF SECURITIES IMPACTED BY U.S. EXECUTIVE ORDER 13959, AS
AMENDED BY EXECUTIVE ORDER 14032 | DECEMBER 2021

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Q&A: MSCI’S TREATMENT OF SECURITIES IMPACTED BY U.S. EXECUTIVE ORDER 13959, AS
AMENDED BY EXECUTIVE ORDER 14032 | DECEMBER 2021

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AMENDED BY EXECUTIVE ORDER 14032 | DECEMBER 2021

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