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On January 13, 2021, President Trump amended the November 12, 2020, Executive Order (EO) 13959 providing greater clarity to the scope of the EO’s ban on trading and investing in certain designated publicly traded securities of “Communist Chinese military companies” (CCMCs). The ban became effective January 11, 2021, but the amended EO, guidance and general licenses issued by the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) add greater clarity on the ban and provide important carve-outs or caveats to its scope. Investors and holders of covered securities should take careful note of these latest developments and anticipate that we will see further guidance, clarifications and possible licenses related to the EO in the coming days and weeks. ....

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