In order to clarify the scope of Executive Order 13959, which prohibits U.S. persons from purchasing publicly traded securities of communist Chinese military companies, the Department of the Treasury’s Office of Foreign Assets Control has released new Frequently Asked Questions. OFAC has also issued a list containing the names of entities identified in or pursuant to E.O. 13959 as communist Chinese military companies, along with additional identifying information where possible. The new FAQs address some – but not all – of the significant ambiguities in the text of the Executive Order. These include the extent to which the prohibitions reach subsidiaries of communist Chinese military companies, challenges in identifying companies covered by the order, the definition of “publicly traded securities,” and the application of the Executive Order to investment funds holding covered securities. On the day of the release of OFAC’s guidance, Secretary of State Michael Pompeo issued a press statement suggesting that the Trump Administration believes that the Executive Order requires U.S. persons to divest from covered securities by a certain date.