What You Need to Know 

• Last week, President Donald Trump signed an order forcing a Chinese-owned company to unwind its 2020 acquisition of a U.S. company—in only the 10^th such divestment order of its kind. 
• The order stem from an identified national security risk related to the “potential compromise of the U.S. company’s products used in military and critical infrastructure environments.” 
• This divestment highlights not only the importance of evaluating Committee on Foreign Investment in the United States (CFIUS) considerations at the outset of any transaction involving foreign investors, but also the continued scrutiny of Chinese investment in the United States. 

On July 11, 2025, the Trump administration published an order forcing Suirui International Co., Limited—a Hong Kong company that is majority owned by Suirui Group Co., Ltd., a People’s Republic of China company—to unwind its acquisition of Jupiter Systems, LLC, a U.S. company and provider of video wall processors and content visualization solutions. The acquisition was completed in February 2020, and the order, which was issued on July 8, 2025, provides Suirui with 120 days (i.e., until November 5, 2025) to divest all interests and rights in Jupiter and its tangible or intangible assets or property, including intellectual property, non-public source code, and customer contracts, as well as Jupiter’s assets and operations in Hong Kong and Shenzen (Jupiter Asia) except for Jupiter Asia assets or operations acquired or created after the acquisition.  

The order also provides that Jupiter will be prohibited from holding any interest or rights in the assets or operations of Jupiter Asia acquired or created after the acquisition. The divestment is subject to CFIUS approval, and until the divestment has been completed, Suirui must comply with interim measures to ensure that its personnel and affiliates do not access 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.  

Why It Happened  

Although neither the order nor the press release from CFIUS provides clear insight into the history of the acquisition (and CFIUS’ review thereof), based on the facts that are known, the order is the result of CFIUS identifying a national security risk related to the “potential compromise of Jupiter’s products used in military and critical infrastructure environments.” In addition, as divestment orders are atypical (there have only been nine since CFIUS’ statutory authority was formally established in 2007), the order also represents a rare case where the national security risk cannot be addressed through implementing mitigation measures that limit the foreign party’s influence over and/or access to the U.S. business’ assets or operations.  

The timing of the order, years after the acquisition, suggests CFIUS’ review took place through the “non-notified” process, through which CFIUS can initiate review of transactions that technically fall within its jurisdiction but were not presented to CFIUS for review. The office of non-notified transactions has been increasingly busy in recent years, reviewing 80 non-notified transactions in 2022 and 60 non-notified transactions in 2023.  

Why It Matters  

The order serves as a reminder that evaluating CFIUS-related considerations at the outset of any transaction involving foreign investors is critically important. Failure to submit mandatory declarations to CFIUS can result in severe penalties. And even when no filing is mandatory, a decision to forego a voluntary CFIUS review for high-risk transactions leaves open the potential for future disruption—including post-closing divestment—if CFIUS calls in the non-notified transaction. 

The order also highlights the continued scrutiny of Chinese investment in the United States, which is illustrative of U.S. policy towards China and the ongoing tensions that have only increased under the second Trump administration. Chinese investment in companies with operations in the United States is not prohibited (in fact, investors from China accounted for the most notices filed with CFIUS in 2023), but it is subject to heightened scrutiny and requires careful structuring to minimize U.S. national security risks (as well as other regulatory compliance risks, such as with respect to export controls and sanctions). The order shows that even though a company may not produce highly sensitive technologies, other risk factors (e.g., government or military contracts) can raise CFIUS concerns, particularly for Chinese investors.  

Although the risk calculation that CFIUS member agencies make when presented with any transaction for review remains unchanged (threat x vulnerability = consequence), the idea of what is important to U.S. national security, and what threatens it, is ever evolving. Parties should not presume CFIUS is not relevant to a transaction without first conducting careful review.