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On January 5, 2021, the White House issued an Executive Order to restrict certain transactions “with persons that develop or control” eight designated software applications, due to their perceived connections with the government of the People’s Republic of China and the Chinese Communist Party. While uncertainties remain on whether the announced restrictions will take full effect in the Biden administration, companies should take note and be prepared to review their use of the designated applications and transactions with the companies that “develop or control” these applications.
The contemplated actions under this Executive Order are intended to take effect 45 days following its release on February 19, 2021. Once effective, the Executive Order would impose restrictions in the form of licensing requirements on “any transaction by any person, or with respect to any property, subject to the jurisdiction of th