The State Administration of Foreign Exchange ("SAFE") promulgated on October 25, 2019 the Circular on Further Promoting Cross-border Trade and Investment Facilitation (Hui Fa [2019] No. 28) ("Circular 28"), to further promote the reform of "Powers, Regulation and Services", to improve the financial capabilities and standards of foreign exchange administration and services entities, and to facilitate cross-border trade and investment. One of the most notable policies in Circular 28 is the elimination of restrictions on non-investment foreign-invested enterprises ("FIEs") from making domestic equity investments with foreign-exchange capital.