OFAC Designates Shanghai Zhisuan Technology, MiraclePlus and Affiliates under PAIPA

On October 19, 2026, the Department of State designated five Chinese entities under the Protecting American Intellectual Property Act of 2022 in connection with theft of trade secrets from U.S. persons, and OFAC added them to the Non-SDN Menu-Based Sanctions List with blocking of property and related menu-based measures. The action targets Shanghai Zhisuan Technology Co Ltd, established by Linwei Ding in 2023, and Qiji Chuangtan Beijing Investment Management Co Ltd (MiraclePlus) plus three controlled affiliates, following Ding’s January 29, 2026 federal conviction on seven counts of theft of trade secrets involving Google’s super intelligence technology.

Who this affects

• For exporters: All property and interests in property of the five entities are blocked, and all transactions with them are prohibited except for the importation of goods, with additional prohibitions on U.S.-jurisdiction foreign exchange and banking transfers.

• For investors: United States persons are prohibited from investing in or purchasing significant amounts of equity or debt instruments of the designated entities, and U.S. financial institutions are prohibited from making loans or providing credits totaling more than $10,000,000 in any 12-month period.

• For counsel/compliance: The designations apply the sanctions in PAIPA Section 2(b)(1)(A), (D), (H), (I), and (J); General License 2 authorizes wind-down of transactions involving MiraclePlus and its three listed affiliates (plus 50 percent owned entities) through 12:01 a.m. eastern standard time January 19, 2027, with payments to blocked persons required into blocked U.S. accounts, while Shanghai Zhisuan Technology Co Ltd is not covered by that license.

• For policymakers: The designations implement PAIPA’s mandate against foreign persons that have engaged in or benefited from significant theft of U.S. persons’ trade secrets occurring on or after January 5, 2023, where the activity is reasonably likely to result in a significant threat to U.S. national security, foreign policy, or economic health.

The read

The record distinguishes the direct beneficiary (Zhisuan, established by the convicted individual and marketed as able to replicate Google’s super intelligence infrastructure) from the supporting venture capital structure (MiraclePlus and its funds). General License 2 provides a defined wind-down window only for the latter group and their 50 percent owned entities, leaving the operating company outside that authorization. This is consistent with PAIPA’s statutory focus on both the knowing engagement/benefit and the provision of significant support, applied here after a U.S. jury conviction for theft of thousands of pages of confidential Google information.

What was the action?

The Department of State announced designations of five entities under PAIPA (50 U.S.C. 1709) connected to People’s Republic of China national Linwei Ding for theft of trade secrets from U.S. persons; OFAC added the entities to the Non-SDN Menu-Based Sanctions List and issued PAIPA General Licenses 1 and 2.

What’s the penalty / scope, and how is it set?

No civil or criminal monetary penalty is stated. The action blocks all property and interests in property of each entity and prohibits all transactions with them except importation of goods; it also prohibits loans from U.S. financial institutions exceeding $10,000,000 in any 12-month period, U.S.-jurisdiction foreign exchange transactions in which the entity has any interest, U.S.-jurisdiction banking transfers involving any interest of the entity, and U.S. persons from investing in or purchasing significant amounts of equity or debt instruments of the entity. These measures are the sanctions specified in PAIPA Section 2(b)(1)(A), (D), (H), (I), and (J).

Who else is exposed?

The primary identifies Shanghai Zhisuan Technology Co Ltd (knowingly engaged in or benefited from the theft), Qiji Chuangtan Beijing Investment Management Co Ltd (MiraclePlus; provided significant financial, material, or technological support for or benefited from the theft), Beijing Qiji Chuangtan Phase I Venture Capital Center Limited Partnership, Beijing Qiji Chuangtan Phase II Venture Capital Center Limited Partnership, and Beijing Qiji Chuangtan Zhiyuan Enterprise Management Center Limited Partnership (owned or controlled by or acting for MiraclePlus). General License 2 additionally covers any entity in which one or more of the MiraclePlus-group entities own, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest. Broader sectors or counterparties beyond these are not specified in the record.

What happens next

General License 2 authorizes transactions ordinarily incident and necessary to the wind down of dealings with MiraclePlus and the three listed partnerships (and qualifying 50 percent owned entities) through 12:01 a.m. eastern standard time on January 19, 2027, after which that authorization expires; the underlying designations and menu-based sanctions remain in effect unless separately modified. General License 1 authorizes transactions prohibited by PAIPA to the extent they are authorized or exempt under the Cyber-Related Sanctions Regulations.

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