On June 3, 2021, the Biden Administration amended a Trump Administration order that had prohibited U.S. persons from engaging in certain types of transactions involving publicly traded and derivative securities of companies listed as Communist Chinese Military Companies (“CCMCs”) pursuant to Section 1237 of the 1999 National Defense Authorization Act. The original Trump Administration order, Executive Order (“E.O.”) 13959, issued in the waning days of that administration, was the subject of considerable confusion as to precisely which CCMCs and affiliated entities were or were not subject to the restrictions. In a further effort to clarify its scope, the Trump Administration eventually amended the original order by issuing E.O. 13974 on January 13, 2021.

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