Charles Schwab Investment Management, Inc. (CSIM) is monitoring the companies impacted by the Executive Order dated November 12, 2020 (Executive Order) as updated by the U.S. Department of Defense (DoD) and the U.S. Treasury’s Office of Foreign Assets Control (OFAC) and has reviewed the holdings of its client accounts, including advised mutual funds and exchange-traded funds (ETFs), against these published lists. CSIM is also consulting with the index providers to the mutual funds and ETFs.

CSIM has implemented restrictions in its trade order management systems to seek to prevent investment in currently identified companies.

This situation remains fluid, and CSIM will continue to monitor announcements from OFAC, DoD, index providers and others to determine appropriate future actions.