A
Private Investor is a recipient of the information who meets all of the conditions set out below, the recipient: 1. Obtains access to the information in a personal capacity; 2. Is not required to be regulated or supervised by a body concerned with the regulation or supervision of investment or financial services; 3. Is not currently registered or qualified as a professional securities trader or investment adviser with any national or state exchange, regulatory authority, professional association or recognised professional body; 4. Does not currently act in any capacity as an investment adviser, whether or not they have at some time been qualified to do so;
Background
On November 12, 2020, U.S. President Donald Trump issued Executive Order 13959 (the Executive Order ), which prohibits U.S. Persons from purchasing publicly traded securities of 35 Chinese companies identified as Communist Chinese Military Companies ( CCMCs ) or engaging in any transaction in any securities that are derivative of, or are designed to provide investment exposure to prohibited CCMC securities. Under the Executive Order, U.S. Persons cannot make purchases of CCMC securities effective January 11, 2021 and have until November 11, 2021 to divest from these securities.
On December 28, 2020, the U.S. Treasury Department s Office of Foreign Assets Control ( OFAC ) issued requirements regarding restrictions and processes in connection with the Executive Order.