Today, a question: does the OFAC 50 Percent Rule apply to the new Chinese Military Companies sanctions program? While I could cheat and give you a quick yes/no, let’s wend our way through Executive Order, the Ukraine/Russia and Venezuela program so we can figure out how to think these things through, rather than running off to OFAC for guidance.

Why did it occur to me to record this on a Sunday morning? Welcome to my life, folks... especially during COVID.

Stay safe out there - wear a mask.