We recently authored an article for Law360 detailing a July 8 order by the Trump administration to block and force the unwinding of a transaction that occurred more than five years ago.

The decision, based on an ex post facto review by the Committee on Foreign Investment in the United States (CFIUS), forced the blocking of the February 2020 acquisition of Jupiter Systems LLC, a U.S.-based audiovisual equipment supplier, by a Chinese-based cloud communication provider, Suirui International Co. Ltd.

“While unusual, this matter highlights the increasing breadth of U.S. national security concerns, especially related to China, and the wide scope CFIUS has to review transactions,” we explained in the article.

The July 8 order is detailed and strict. As a starting point, it requires Suirui to sell all Jupiter assets, with limited exceptions, within 120 days, unless an extension is granted. Publicly available information suggests that Jupiter is a supplier to U.S. government entities involved in national security and intelligence operations, likely contributing to the July 8 order.

“It is not clear how CFIUS became aware of the transaction or the extent to which CFIUS conducted its review with any involvement or even the awareness of Jupiter and Suirui. What is clear is that the order reflects ongoing concerns regarding acquisitions involving Chinese investors,” we explained. “While there have been only a few presidential actions requiring the ex post facto blocking of a transaction, the majority have involved Chinese investors or affiliates.”

Going forward, CFIUS will remain interested in foreign investment in a company that has meaningful contracts with the U.S. government. There is benefit to companies going through the CFIUS process in that it offers predictability by avoiding a potential order several years in the future that dismantles the deal, similar to the Jupiter acquisition.

The full article, “Divest Order Shows How Security Fears Extend DFIUS Scope,” was published by Law360 on August 21 and is available online (subscription required). A PDF of the article is available here. In addition, we authored a blog post in July 2025 about this topic, “CFIUS and President Trump Force Unwinding of 2020 Acquisition of Jupiter Systems, LLC.”