The U.S. government has sanctioned five China-based entities, among them the Beijing venture investor MiraclePlus and two of its yuan-denominated funds, under a 2022 law aimed at foreign beneficiaries of trade-secret theft, according to a notice the Treasury Department's Office of Foreign Assets Control posted Monday. The State Department said the five are connected to Linwei Ding, a former Google engineer convicted in January of stealing the company's trade secrets. The action uses financial penalties, not just prosecution, against an investment firm, and it gives U.S. banks and investors with any exposure to these entities immediate compliance work.
What Happened
OFAC, the Treasury office that administers sanctions, listed the entities under the Protecting American Intellectual Property Act of 2022, known as PAIPA. They are Qiji Chuangtan Beijing Investment Management Co Ltd, also known as MiraclePlus; its Phase I and Phase II venture capital partnerships, which the notice also calls MiraclePlus RMB Fund I and Fund II; Beijing Qiji Chuangtan Zhiyuan Enterprise Management Center; and Shanghai Zhisuan Technology Co Ltd. The notice says the three MiraclePlus partnerships are linked to the management company, and that Shanghai Zhisuan was established Oct. 17, 2023.
Each entity faces the same five measures. Its property under U.S. jurisdiction is blocked, except for imports of goods. U.S. financial institutions may not lend it more than $10 million in any 12-month period. Foreign-exchange deals and bank payments involving its interests are barred within U.S. jurisdiction. And U.S. persons may not invest in or buy significant amounts of its equity or debt.
The entities were added to OFAC's Non-SDN Menu-Based Sanctions List, which OFAC keeps apart from its main Specially Designated Nationals list for targets whose penalties are picked from a menu set by law.
OFAC issued two general licenses, standing permissions that soften the impact. General License 2 allows dealings needed to wind down transactions with the four MiraclePlus entities, and with companies they own 50% or more, until 12:01 a.m. Eastern time Jan. 19, 2027, provided payments go into a blocked U.S. account. Shanghai Zhisuan is not covered by that wind-down. General License 1 authorizes transactions already permitted under the separate Cyber-Related Sanctions Regulations.
The Google Case
The Treasury notice names no individual. A State Department statement issued the same day says the five entities are connected to Ding, a Chinese national who it says stole thousands of pages of Google's trade secrets "to benefit himself and China-based tech companies." A federal jury in San Francisco convicted Ding on Jan. 29 of seven counts of economic espionage and seven counts of theft of trade secrets covering the hardware and software behind Google's AI supercomputing data centers, including its Tensor Processing Unit chips, the Justice Department said. The State Department did not explain how each entity is linked to him.
Trial evidence points to two links, according to The Wire China. Ding incorporated Shanghai Zhisuan Technology in October 2023, consistent with the founding date in the Treasury listing. The next month he signed an agreement giving MiraclePlus, an incubator modeled on Y Combinator, a 7% stake in his company. Prosecutors said he deceived both Google and MiraclePlus to win admission to its program.
How the Law Works
PAIPA became law Jan. 5, 2023, according to the statute's text. It requires the president to report to Congress on foreign people and companies that knowingly engaged in or benefited from significant theft of U.S. trade secrets on or after that date, when the theft threatens U.S. national security, foreign policy or economic stability. It also reaches those who financed or supported such theft and entities owned or controlled by them. For each identified company, the law requires at least five of 12 listed penalties. Treasury chose exactly five here.
The first designations under the law came Feb. 24, 2026, and targeted a Russia-based network that brokered zero-day exploits, previously unknown software flaws, ABA Banking Journal reported.
Why It Matters
By reaching a venture firm and its funds, the government is signaling that backing a startup tied to trade-secret theft can carry penalties of its own. Funds that co-invested alongside MiraclePlus, limited partners and banks that process its payments will need to check their exposure before the wind-down period ends.
For boards of U.S. technology companies, the case is a reminder that insider theft of trade secrets is treated as a national security matter, with consequences that can extend to a startup's backers. The law's menu holds seven more penalties Treasury did not use, among them placement on the Entity List and limits on U.S. government procurement, which leaves room to escalate.
What to Watch
Look for a fuller government account of how each entity is linked to Ding. Other signals: whether Beijing responds, how companies in MiraclePlus's portfolio and its foreign co-investors react, whether OFAC adds more PAIPA targets, and whether it extends or lets lapse the Jan. 19 wind-down deadline.
