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In late 2015, as the Chinese currency Renminbi depreciated severely and the Chinese foreign exchange reserve went down dramatically, the State Administration of Foreign Exchange (the “SAFE”) started to issued a new policy for tightening its control over the outflow of foreign capital investment, foreign commercial loans or non-trading related foreign payments. Such a new policy was introduced orally via an internal “Window Guidance” to the banks in China. As a consequence, certain foreign exchange transactions that had beenwere permitted before the issuance of the new policy become impossible. The Sstandby letter of credit (the “SBLC”) was one of those transactions to be affected.
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