On September 18, 2020, the Department of Commerce identified prohibited transactions relating to mobile applications (“Apps”) TikTok and WeChat, as required by Executive Orders 13942 and 13943, respectively. The prohibitions, which were originally to take effect on September 20, include prohibitions on the provision of services related to the distribution and functioning of the TikTok and WeChat Apps, including for the purpose of transferring funds or processing payments to or from parties within the United States through the WeChat App, but only apply to “business-to-business transactions” and include several carve-outs. The effective dates for most of the prohibited transactions have now been delayed. Certain prohibitions with respect to TikTok related to the distribution or maintenance of the App were supposed to become effective September 20, but the Department of Commerce postponed the effective date to September 27 after President Trump approved the deal in concept between Oracle Corp., Walmart Inc., and ByteDance Ltd., the owner of Tiktok, which would allow TikTok to divest itself of its U.S. assets and U.S. user data in line with a separate executive order. Most of the other prohibitions for TikTok will become effective beginning on November 12, 2020, which allows certain functionality while CFIUS’ work related to the Oracle, Walmart, and ByteDance deal remains ongoing. The prohibitions with respect to WeChat were supposed to become effective as of September 20, 2020, but a Magistrate Judge for the U.S. District Court for the Northern District of California granted a preliminary injunction on September 19, ruling that the plaintiffs in U.S. WeChat Users Alliance v. Donald J. Trump had shown serious questions going to the merits of their First Amendment claim.