US Sanctions MiraclePlus and Four Other Chinese Entities Under PAIPA, Linked to Former Google Engineer Linwei Ding
The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) on October 19 listed MiraclePlus and its affiliated funds, along with five entities including Shanghai Zhisuang Technology, under menu-based sanctions pursuant to the 2022 Protecting American Intellectual Property Act (PAIPA), implementing asset freezes.
The listed entities include MiraclePlus Beijing Investment Management LLC, Beijing MiraclePlus Phase I and II Venture Capital Center Limited Partnership, Beijing MiraclePlus Zhiyuan Enterprise Management Center Limited Partnership, and Shanghai Zhisuang Technology Co., Ltd. The sanctions include asset freezes, restrictions on U.S. loans and foreign exchange transactions, and prohibitions on U.S. persons from making specific equity and debt investments.
The U.S. State Department stated that these entities are linked to former Google engineer Linwei Ding. Ding was convicted on January 29, 2026, by a federal jury on seven counts of trade secret theft involving thousands of pages of Google’s superintelligence technology secrets. He founded Shanghai Zhisuang Technology in 2023 and claimed during a pitch at MiraclePlus's startup camp that he could replicate Google-related infrastructure technology, with MiraclePlus providing seed funding and acquiring equity.
OFAC simultaneously issued two general licenses. License 2 authorizes necessary wind-down transactions for MiraclePlus and its three affiliated partnerships (and entities with over 50% ownership) until 12:00 AM EST on January 19, 2027, but payments to frozen entities must go into frozen accounts within the U.S. Shanghai Zhisuang Technology is not included in the wind-down license.
Funds and transactions are facing pressure from freezes and exits. Contracts, investments, and payments within U.S. jurisdiction must conclude during the transition period, benefiting the U.S. intellectual property protection mechanism, while LPs and partners interacting with these entities must bear compliance and liquidation costs.
Source: Public Information
ABAB AI Insight
PAIPA came into effect in 2023, authorizing menu-based sanctions against foreign entities that knowingly benefit significantly from the theft of trade secrets from U.S. entities. This action stems from investigations by the Department of Justice and the FBI into Linwei Ding, who was found to have stolen superintelligence-related secrets during his tenure at Google and later founded Shanghai Zhisuang Technology in China, receiving seed investment from MiraclePlus. The path extends from criminal conviction to administrative sanctions against investors and affiliated funds.
The capital path focuses on cutting off U.S. jurisdiction funds and transactions: asset freezes, loan and investment restrictions, while providing a wind-down window until January 19, 2027, through general licenses. The strategic motive is to extend sanctions from direct thieves to the venture capital network that provides funding and platform support, increasing the costs of cross-border technology transfer.
Similar cases include previous OFAC actions against trade secret theft and restrictions on Chinese entities' technology acquisition channels. We are currently in a phase of expanding from criminal accountability to sanctions on investment networks, with MiraclePlus being included as a Chinese tech startup incubator.
Essentially, this represents regulatory changes and capital path disruptions. The U.S. links intellectual property theft to investment support through PAIPA, with mechanisms involving menu-based sanctions that freeze jurisdictional assets and restrict new transactions, forcing funds interacting with sanctioned entities to exit during the transition period while increasing compliance risks for Chinese AI-related startup support.
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Administrative sanctions follow after criminal convictions
The wind-down window provides time, but funds go into frozen accounts