Memo 12631MemorandumTrump 45 · R Quiet signal

Presidential Memorandum 12631

Protecting United States Investors From Significant Risks From Chinese Companies

This presidential memorandum directs the Secretary of the Treasury to convene the President's Working Group on Financial Markets (PWG) to address risks to U.S. investors from Chinese companies that evade American securities transparency requirements, particularly by blocking PCAOB access to audit working papers. The PWG must submit recommendations within 60 days for executive branch, SEC, and PCAOB actions to protect investors, including potential new listing rules and governance safeguards.

Impact dates

  1. PWG report due to President with recommendations

Key directives

  • Secretary of the Treasury shall convene the PWG to discuss investor risks from Chinese government transparency failures
  • PWG shall submit report within 60 days with recommendations for executive branch actions to protect investors
  • PWG shall recommend SEC or PCAOB inspection/enforcement actions against non-compliant audit firms
  • PWG shall recommend additional SEC or federal agency actions including notice of proposed rulemaking for new listing rules or governance safeguards
  • Secretary of the Treasury authorized and directed to publish this memorandum in the Federal Register

Who is ordered

Timeline

Immediate

  • PWG convening ordered
  • Treasury Secretary directed to act

Near term (90d)

  • PWG report due with recommendations for executive branch actions
  • PWG report due with SEC/PCAOB inspection and enforcement recommendations
  • PWG report due with recommendations for new listing rules/governance safeguards via notice of proposed rulemaking

Long term

  • Potential implementation of new listing standards for Chinese companies
  • Possible delisting pressure on non-compliant Chinese firms
  • Broader application to other countries' non-compliant companies

Risks & tensions

  • Tension between enforcing transparency and avoiding negative effects on American investors and markets (explicitly acknowledged in text)
  • Potential for market disruption if Chinese companies face delisting or restricted access
  • Vague scope: 'other countries that do not comply' opens door beyond China but provides no criteria
  • Relies on recommendations rather than mandating specific regulatory actions—implementation uncertain
Presidential Memorandum 12631: Protecting United States Investors From Significant Risks From Chinese Companies · Executive Orders