Consolidated Comment on the "Communist Chinese Military Companies" Executive Order, as Amended and as it Existed Prior to June 3, 2021

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TURBOFAC Commentary (6840 words)

Consolidated Comment on the "Communist Chinese Military Companies" Executive Order, as Amended and as it Existed Prior to June 3, 2021

 

On June 3, 2021, EO 14032 was issued, thereby significantly altering the nature of the sanctions related to certain Chinese securities. For consolidated commentary on the regime as it exists under EO 14032, see Consolidated Comment on the Chinese Military Companies Sanctions Under the EO Issued June 3, 2021.

 

The below will remain on the Research System as it existed on June 3, 2021, for lookback purposes.

 

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I) BACKGROUND

 

The “Chinese Military Companies” EO 13959, as amended by EO 13974 (“CMC EO”), prohibits U.S. persons from engaging in “transactions” of any “publicly traded security,” or any “securities...