On October 19, 2026, the U.S. Department of State designated five China-based entities under the Protecting American Intellectual Property Act (PAIPA), citing significant theft of trade secrets belonging to U.S. persons. The measures block property and restrict specified transactions, lending, foreign exchange, banking and investment. The designations are administrative actions, not criminal convictions of the entities.
The five entities named under PAIPA
The State Department said former Google engineer Linwei Ding established Shanghai Zhisuan Technology in 2023. It said the company was presented as able to replicate Google’s superintelligence infrastructure. The department also said venture-capital firm MiraclePlus provided Zhisuan seed funding in exchange for an ownership stake, manages two of the other designees, and is linked through ownership to the fifth.
| Designated entity | Relationship described by the State Department |
| Shanghai Zhisuan Technology Co Ltd | Established by Linwei Ding in 2023. The State Department characterized it as having knowingly engaged in or benefited from significant trade-secret theft. |
| Qiji Chuangtan Beijing Investment Management Co Ltd (MiraclePlus) | Provided seed funding to Zhisuan in exchange for an ownership stake; the State Department characterized it as providing significant support connected to the alleged theft. |
| Beijing Qiji Chuangtan Phase I Venture Capital Center Limited Partnership | Managed by MiraclePlus; wholly owns Zhiyuan Enterprise. |
| Beijing Qiji Chuangtan Phase II Venture Capital Center Limited Partnership | Managed by MiraclePlus. |
| Beijing Qiji Chuangtan Zhiyuan Enterprise Management Center Limited Partnership | Wholly owned by Phase I. |
The State Department described the findings as the basis for its PAIPA designations. The OFAC designation notice lists all five entities and the sanctions provisions applied to them.
What the restrictions cover
OFAC applied PAIPA Sections 2(b)(1)(A), (D), (H), (I) and (J). The resulting measures cover several types of property and financial activity, with different conditions for each.
| Measure | Scope and condition |
| Property | Property and interests in property of each designated entity are blocked. |
| Transactions | Covered transactions involving the entities are prohibited, with an exception for importing goods. |
| Loans and credits | U.S. financial institutions may not provide loans or credits totaling more than $10 million to an entity in any 12-month period, subject to an exception in the statute. |
| Foreign exchange and banking | Specified foreign-exchange transactions within U.S. jurisdiction and covered transfers or payments involving an entity’s interest are prohibited. |
| Investment | U.S. persons may not invest in or purchase significant amounts of an entity’s equity or debt. |
A limited wind-down license runs through January 2027
OFAC General License No. 2 authorizes specified transactions ordinarily incident and necessary to winding down transactions involving MiraclePlus, the Phase I and Phase II funds, Zhiyuan Enterprise, and entities at least 50% owned by one or more of them. It runs through 12:01 a.m. Eastern Standard Time on January 19, 2027. Payments to a blocked person must go into a blocked account in the United States. The license text sets out the authorization’s conditions.
Ding’s criminal case is separate
A federal jury convicted Linwei Ding on January 29, 2026, on seven counts of trade-secret theft and seven counts of economic espionage, according to the U.S. Department of Justice. The South China Morning Post later reported that a judge acquitted Ding on the seven espionage counts while the theft convictions remained.
Those proceedings concerned Ding, not the five entities designated in October. The State Department’s PAIPA findings are administrative designations; they are not criminal verdicts against the companies or partnerships.
