On June 3, 2021, the Biden administration issued Executive Order (“E.O.”) 14032, which replaces the ban on transacting in securities of Chinese military companies that was established by the Trump administration in E.O. 13959. The basis for designating sanctions targets has been revised; rather than targeting “Communist Chinese Military Companies” identified by the Department of Defense under the statutory requirements of Section 1237 of the National Defense Authorization Act for Fiscal Year 1999, as amended, the revised framework gives the Treasury Department primary authority to designate companies operating in China’s defense or surveillance technology sectors, termed “Chinese Military-Industrial Complex” or “CMIC” companies, as subject to the transaction ban.
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