OFAC Adds Five PAIPA Entities and Issues Two General Licenses

What's on the official record

On 19 October 2026, the Office of Foreign Assets Control (OFAC) issued two general licenses and added five entities to its Non-SDN Menu-Based Sanctions List (NS-MBS List) under the Protecting American Intellectual Property Act of 2022 (PAIPA). The page cites no Executive Order for this action.

OFAC issued Protecting American Intellectual Property Act of 2022 (PAIPA) General License 1, "Transactions Authorized Pursuant to the Cyber-Related Sanctions Regulations," and PAIPA General License 2, "Authorizing the Wind Down of Transactions Involving Certain Entities Blocked on October 19, 2026."

The five entities added, each tagged [PAIPA], are:

BEIJING QIJI CHUANGTAN PHASE I VENTURE CAPITAL CENTER LIMITED PARTNERSHIP (a.k.a. MIRACLE PLUS RMB FUND I), USCC 91110108MA01QB5K5M
BEIJING QIJI CHUANGTAN PHASE II VENTURE CAPITAL CENTER LIMITED PARTNERSHIP (a.k.a. BEIJING QIJICHUANGTANERQI CHUANGYE INVESTMENT CENTER (LIMITED PARTNERSHIP); a.k.a. MIRACLE PLUS RMB FUND II), USCC 91110108MABQAUYK7G
BEIJING QIJI CHUANGTAN ZHIYUAN ENTERPRISE MANAGEMENT CENTER LIMITED PARTNERSHIP, USCC 91110108MA01NK6F9X
QIJI CHUANGTAN BEIJING INVESTMENT MANAGEMENT CO LTD (a.k.a. MENGXI CHUANGTAN BEIJING INVESTMENT MANAGEMENT CO LTD; a.k.a. MIRACLEPLUS), USCC 91110108MA01HHAHXF
SHANGHAI ZHISUAN TECHNOLOGY CO LTD, USCC 91310104MAD3LXU92B

The first four entities are listed as "Linked To: QIJI CHUANGTAN BEIJING INVESTMENT MANAGEMENT CO LTD." Each entity carries PAIPA Section 2 blocking information, including blocking of property, a ban on loans from United States financial institutions totaling more than $10,000,000 in any 12-month period, and a ban on United States persons investing in or purchasing significant amounts of equity or debt instruments of the entity.

Assessment

For a sanctions or trade-finance committee, the record lists five China-based entities and their Unified Social Credit Codes, which the committee can screen against its counterparty and transaction records. The record sets out the PAIPA Section 2 prohibitions — including the $10,000,000 12-month loan cap and the ban on significant equity or debt investment — that define what a United States financial institution must hold or enhance diligence on. The two general licenses frame the wind-down window for transactions involving the entities blocked on 19 October.

For an owner or operating executive, the record names the five entities and their aliases, which the executive can check against its own investor, vendor, and counterparty lists. The record's PAIPA Section 2 blocking information states the transactions that are prohibited, so the executive can determine whether any existing relationship falls within the wind-down authorization of General License 2. The record lets the executive decide whether to stay, delay, or exit a relationship before a buyer or lender checks.

What would change this call

A State Department parallel release or the full text of the two general licenses could state the policy rationale and the precise scope and expiry of the wind-down authorization. Additional NS-MBS List entries or alias changes would alter the screening set.

What to check next

Check	Why it matters
Full text of PAIPA General License 2	Wind-down scope and expiry define the transition window
Full text of PAIPA General License 1	Confirms which cyber-related transactions remain authorized
NS-MBS List entries for the five entities	USCC and alias mapping for screening
State Department parallel release	States the policy rationale and alleged conduct

Confidence

Filed 25 October 2026 from the record dated 19 October 2026. The record is the authoritative OFAC recent-actions page for 19 October 2026, and all entities, identifiers, and license titles are reported exactly as listed there.

Sources

[1] OFAC Recent Actions, "Protecting American Intellectual Property Act of 2022 (PAIPA) Designations; Issuance of Associated General Licenses," 19 October 2026, https://ofac.treasury.gov/recent-actions/20261019