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Wednesday, February 17, 2021 This alert addresses recent developments relating to former President Trump s executive orders on Chinese Military Companies that affect both investors in covered securities and exporters. OFAC s Frequent Asked Questions On November 12, 2020, former President Trump issued an executive order ( EO ), pursuant to the National Defense Authorization Act for Fiscal Year 1999, as amended ( NDAA ), prohibiting U.S. persons from investing in publicly traded securities of any person designated by the Secretary of Defense or the Secretary of the Treasury as a Communist Chinese military company ( Chinese Military Company ). See our analysis of the Nov. 12 EO  here. Since then, the 2021 National Defense Authorization Act ( 2021 NDAA ) was enacted into law, the EO was amended, the list of Chinese Military Companies expanded, and frequently asked questions promulgated.

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