US: OFAC Blocks MiraclePlus Under PAIPA Menu Sanctions

On October 19, 2026, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) added five Chinese entities to the Non-SDN Menu-Based Sanctions List (NS-MBS List) under the Protecting American Intellectual Property Act of 2022 (PAIPA) and issued PAIPA General License 1 and PAIPA General License 2. The names are Qiji Chuangtan Beijing Investment Management Co Ltd (奇绩创坛北京投资管理有限责任公司), also known as MiraclePlus and as Mengxi Chuangtan Beijing Investment Management Co Ltd, its Phase I and Phase II funds, Beijing Qiji Chuangtan Zhiyuan Enterprise Management Center Limited Partnership, and Shanghai Zhisuan Technology Co Ltd (上海至算科技有限公司). US banks and payment institutions that clear dollar or foreign-exchange transfers involving MiraclePlus (Qiji Chuangtan Beijing Investment Management), its Phase I and Phase II funds, Zhiyuan Enterprise, or Shanghai Zhisuan Technology, US financial institutions considering loans or credits above $10,000,000 in a 12-month period to those entities, US persons and funds that hold or would buy equity or debt of MiraclePlus or the two Miracle Plus RMB funds, and US companies with open contracts or payments involving Shanghai Zhisuan Technology or the MiraclePlus group must immediately screen the five entities and entities they own 50 percent or more against the NS-MBS list, block their property, and stop new prohibited transactions, or dealings that stay prohibited are strict-liability OFAC violations, with blocked property that cannot move without a license and civil penalties under the International Emergency Economic Powers Act (IEEPA).

The 50 percent screen is OFAC's 50 Percent Rule for blocked persons: an entity owned 50 percent or more in the aggregate by blocked persons is itself blocked even when it is not named on the list. Section 2(b)(1)(J) prohibits any United States person from investing in or purchasing significant amounts of equity or debt instruments of each listed entity. Property blocking under section 2(b)(1)(A) is separate: all property and interests in property of the entity are blocked, and all transactions with it are prohibited, except the importation of goods. OFAC published the designations on its October 19, 2026 recent-actions page.

What did OFAC place on the NS-MBS list on October 19, 2026?

OFAC listed the manager, two funds, one enterprise vehicle and one Shanghai company. They share, except Shanghai Zhisuan, No. 601, 6th Floor, No. 28 Chengfu Road, Haidian District, Beijing. The funds' Chinese names are 北京奇绩创坛一期创业投资中心有限合伙 and 北京奇绩创坛二期创业投资中心有限合伙. Zhiyuan's is 北京奇绩创坛致远企业管理中心有限合伙. Phase II is also known as Beijing Qijichuangtanerqi Chuangye Investment Center. The three partnerships are linked to Qiji Chuangtan. Shanghai Zhisuan sits at 44 Gongwei, Floor 1, Building 27, No. 487 Tianlin Road, Xuhui District, Shanghai.

Which PAIPA menu items apply to each of the five names?

The same five menu items apply to every name. Section 2(b)(1)(A) blocks property and prohibits transactions, except importation of goods. Section 2(b)(1)(D) bars loans or credits above $10,000,000 in any 12-month period, subject to the exception in that paragraph. Section 2(b)(1)(H) bars US-jurisdiction foreign exchange in which the entity has an interest. Section 2(b)(1)(I) bars US-jurisdiction credit transfers and payments that involve any interest of the entity. Section 2(b)(1)(J) bars a United States person from investing in or purchasing significant amounts of equity or debt of the entity.

The same release issued 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."

Who must screen, block and stop new dealings immediately?

US banks and payment institutions that clear dollar or foreign-exchange transfers in which any of the five has an interest must screen and block. US financial institutions must not make loans or provide credits above $10,000,000 in any 12-month period, subject to the section 2(b)(1)(D) exception. US persons must not invest in or purchase significant amounts of equity or debt of the listed entities. US companies with open contracts or payments involving Shanghai Zhisuan Technology or the MiraclePlus group must stop new prohibited transactions. The 50 Percent Rule extends the block to an entity those blocked persons own at 50 percent or more in the aggregate, even when that entity is not itself on the NS-MBS list. Importation of goods remains outside section 2(b)(1)(A). Continuous, per-jurisdiction monitoring surfaces a list change of this kind the moment OFAC publishes it.

What is the consequence if a prohibited dealing continues?

A dealing that stays prohibited is a strict-liability OFAC violation: civil penalties attach without a requirement to prove intent, blocked property cannot move without a license, and IEEPA civil penalties apply.

Check open payments, foreign-exchange bookings, loans, credit lines, and any new purchase of equity or debt against the five names, and screen entities they own 50 percent or more under the 50 Percent Rule. Block what section 2(b)(1)(A) blocks, except importation of goods, and stop new dealings that sections 2(b)(1)(D), (H), (I) and (J) prohibit.