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On July 8, 2025, President Trump issued an order (the “Order”) requiring a Chinese company, Suirui Group Co., Ltd., and its Hong Kong subsidiary, Suirui International Co., Limited (collectively, “Suirui”), to divest its interest and rights in Jupiter Systems, LLC (“Jupiter”), a California-based company specializing in video processing technology.

Suirui acquired Jupiter in 2020, and the Committee on Foreign Investment in the United States (“CFIUS”) subsequently reviewed the transaction.  In connection with its review, CFIUS identified national security risks arising from Suirui’s ownership of Jupiter.  In particular, the U.S. Department of Treasury issued a statement explaining that CFIUS had identified a national security risk arising from the use of Jupiter’s products in the military and critical infrastructure environments, which could be compromised under Chinese ownership.

Link to Divestment Timeline and Requirements Divestment Timeline and Requirements

The Order (i) requires Suirui to divest all interests and rights in Jupiter, including all of Jupiter’s tangible and intangible assets or property, wherever located, within 120 calendar days, and any assets or operations of its Asian subsidiaries acquired or created after the completion of the transaction and (ii) excludes certain assets and operations acquired or created by Jupiter’s Asian subsidiaries after Suirui’s 2020 acquisition of Jupiter.

The Order also implements certain access restrictions, which prohibit Suirui and its personnel from accessing Jupiter’s non-public source code, information technology systems, products, parts and components, books and records, non-public technical information, and facilities in the United States.  The Order further requires Jupiter and Suirui to submit weekly certifications to CFIUS confirming compliance with the Order and describing efforts to effectuate the divestment.  Furthermore, Suirui must notify CFIUS before selling its interests and rights in Jupiter to a third party, which will then be subject to CFIUS’s non-objection.

Link to Broader Implications Broader Implications

The Order represents the first CFIUS divestiture order under the second Trump administration (and only the tenth-ever Presidential order to block or prohibit a transaction following a CFIUS review).  The Order is consistent with President Trump’s America First Investment Policy, previously discussed here, which aims to restrict China’s access to “cutting-edge technologies, intellectual property, and leverage in strategic industries” through deliberate and organized investment in U.S.-based companies.  The Order also is consistent with CFIUS’s heightened focus on Chinese involvement in the U.S. government and critical infrastructure supply chains.  The order signals that transactions involving Chinese investors will continue to be under significant CFIUS scrutiny—including completed transactions not previously reviewed by CFIUS.