Chinese Military Companies Trading Ban: Overview of OFAC’s Ongoing Guidance

On November 12, 2020, the Trump Administration issued an Executive Order prohibiting U.S. persons from trading securities and related derivatives in “Communist Chinese Military Companies” (CCMCs), effective 60 days later on January 11, 2021, and then extended to January 28, 2021. The Order, which was amended on January 13, 2021, prohibits U.S. persons from “any transaction in publicly traded securities, or any securities that are derivative of, or are designed to provide investment exposure to...
By: Proskauer Rose LLP

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