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.