On July 11, 2025, President Donald Trump issued an Executive Order directing that the February 2020 acquisition of Jupiter Systems, LLC of Delaware, and several of its foreign based subsidiaries (Jupiter), by Suirui International Co., Ltd. (Suirui), a Hong Kong/Chinese company, be unwound. Stating only that there is “credible evidence” Suirui might take action that threatens to impair the national security of the United States, the president has ordered that divestment occur within the next 120 days, unless an extension is granted.

The authority of the president to suspend or prohibit certain foreign investment transactions is pursuant to Section 721 to the Defense Production Act of 1950, as amended, and implementing regulations governing the Committee on Foreign Investment in the United States (CFIUS). The Executive Order requires that Suirui divest “all interests and rights” in Jupiter, Jupiter’s tangible and intangible assets or property, including its intellectual property, non-public source code associated with Jupiter products, and most customer contracts. The assets and operations of two Jupiter subsidiaries located in China and Hong Kong are not required to be divested, so long as such assets and operations were acquired or created after the February 2020 acquisition by Suirui.

Beginning immediately, Suirui must ensure that their personnel “refrain from accessing Jupiter’s non-public source code, non-public technical information, information technology systems, products, parts and components, books and records, or facilities in the United States, unless otherwise approved by CFIUS.” 

In order to effectuate the divestment, Suirui must identify and obtain approval from CFIUS for the intended buyer of Jupiter and its assets. In doing so, it must certify in writing to CFIUS that it has destroyed or transferred all intellectual property or non-public source code associated with Jupiter products in their possession or control. CFIUS has authority to audit the divestment to ensure such destruction or transfer has occurred. CFIUS will implement measures it deems necessary and appropriate to verify and enforce compliance with this Executive Order and any conditions imposed by CFIUS during the period of divestment.

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Photo of Samir D. Varma Samir D. Varma

Samir advises multinational corporations on export controls, economic sanctions and customs, and counsels individuals and corporations on the Foreign Corrupt Practices Act (FCPA) and other anti-corruption laws. He represents clients in enforcement actions before U.S. regulatory agencies and conducts corporate internal investigations.

Photo of Scott E. Diamond** Scott E. Diamond**

Scott is a senior policy advisor with more than 25 years’ experience with the legislative and regulatory processes involved in international trade policy, remedies and enforcement. This includes working with clients on matters involving export controls, economic sanctions, human rights and forced labor…

Scott is a senior policy advisor with more than 25 years’ experience with the legislative and regulatory processes involved in international trade policy, remedies and enforcement. This includes working with clients on matters involving export controls, economic sanctions, human rights and forced labor compliance, corporate anti-boycott and antibribery compliance, national security investigations, and foreign direct investment in the United States.

**Not licensed to practice law.

Photo of Francesca M.S. Guerrero Francesca M.S. Guerrero

Francesca counsels clients on compliance with export controls, sanctions, import regulations, human rights and forced labor, and the FCPA and antibribery laws. She works closely with companies to develop tailored compliance programs that fit their specific needs, and routinely advises clients on some…

Francesca counsels clients on compliance with export controls, sanctions, import regulations, human rights and forced labor, and the FCPA and antibribery laws. She works closely with companies to develop tailored compliance programs that fit their specific needs, and routinely advises clients on some of their most challenging international transactions, involving dealings in high-risk jurisdictions or with high-risk counterparties. Francesca also counsels companies through all phases of internal investigations of potential trade and antibribery violations and represents companies across industries before related government agencies.