I. Overview
With just one week remaining in his term, President Trump amended Executive Order (“
EO”) 13959, which prohibits U.S. persons from investing in the securities of Chinese Military Companies (“
CMCs”), to continue his aggressive stance toward such CMCs. The amended EO now generally prohibits all transactions (rather than just investments) in CMC securities and requires U.S. persons to divest themselves of all such securities by November 11, 2021, and within 365 days for future listed CMCs. We discussed the earlier version of EO 13959 at length in a previous client alert, and OFAC’s interpretations of key terms (which generally remain valid) in another client alert.