Sanctions modified on Chinese military-industrial complex companies

President Biden modifies sanctions on Chinese military-industrial complex companies

President Biden has issued an Executive Order to modify sanctions initially imposed by former President Trump regarding investments in Chinese companies with alleged ties to the Chinese military. The order means that restrictions will be in place going forward. There had been speculation that President Biden would simply lift the sanctions.  

The Executive Order replaces and supersedes an Executive Order issued by former President Trump in November 2020. 

The White House released a Fact Sheet on the modifications. The key changes in President Biden’s Executive Order include: 

  • Expanded set of investment services that US persons can provide when acting for non-US funds, investors or companies 
  • Divestment of securities of Chinese companies that become listed is no longer required 
  • Only explicitly listed entities will be subject to the sanctions 
  • The US Government’s criteria for sanctions designation are refined 
  • These sanctions are now decoupled from defense spending legislation that authorized lists. 

We can help 

As well as our teams in Chicago and New York, Bovill has regulatory experts in London, Singapore and Hong Kong. We also have a highly specialist financial crime team who are experienced in cross-border challenges and always abreast of international sanctions. Get in touch if we can help. 

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