Letter to Jamie Dimon (CEO of JPMorgan Chase & Co.)
April 17, 2025
Mr. Jamie Dimon
Chairman and Chief Executive Officer
JPMorgan Chase & Co.
383 Madison Avenue
New York, NY 10179
Dear Mr. Dimon,
We are writing to express significant concerns regarding JPMorgan Chase & Co. (JPMorgan)’s involvement in the upcoming Hong Kong initial public offering (IPO) of Contemporary Amperex Technology Co., Limited (CATL)—a Chinese military company as designated by the U.S. Department of Defense under Section 1260H of the National Defense Authorization Act (NDAA).
If JPMorgan proceeds with underwriting CATL’s IPO, it risks supporting a company linked to the ongoing genocide of Uyghur Muslims in Xinjiang, the erosion of American manufacturing, and the endangerment of U.S. service members. Over the last two decades, Chinese submarines have repeatedly stalked U.S. warships, at times operating undetected within striking distance. In one incident, a Chinese attack submarine surfaced within torpedo range of an American aircraft carrier. Indeed, Admiral Sam Paparo, Commander of the U.S. Indo-Pacific Fleet, has stated that China’s advanced submarines “were built to threaten the United States.”
During his tenure as the senior U.S. Senator from Florida, Secretary of State Marco Rubio and twenty-six other Republican and Democrat Members of Congress warned that CATL’s lithium-ion batteries may soon power China’s conventional submarine fleet, replacing older lead-acid batteries with advanced lithium-ion technology.
CATL’s designation by the Pentagon under the 1260H List is intended to alert U.S. entities and investors to the company’s affiliations with the People’s Liberation Army (PLA) and broader Chinese state objectives—particularly involving dual-use technologies critical to military and surveillance applications. CATL’s industry-leading role in battery manufacturing—a sector explicitly targeted by China's "civil-military fusion" policy—poses significant risks to U.S. investors and national security.
Moreover, CATL maintains a close, tier-one supplier relationship with the Xinjiang Production and Construction Corps (XPCC), a paramilitary entity of the Chinese state that operates forced labor camps and is directly tied to the ongoing genocide of Uyghur Muslims in Xinjiang. XPCC was the foundational entity written into the Uyghur Forced Labor Prevention Act (UFLPA) and is connected to mass arbitrary detention, severe physical abuse, and other human rights abuses targeting Uyghurs and other ethnic minorities in the region.
For your convenience, we are attaching our 2024 letter—co-signed by Chairman Mark Green of the House Committee on Homeland Security and former Senator Marco Rubio—mapping over half a dozen connections between CATL and Chinese entities directly involved in the Uyghur genocide.
We are troubled by reports that JPMorgan and other American banks aggressively pursued the IPO of CATL, despite its public designation as a Chinese military company and its ties to sanctioned entities. Senior executives reportedly prioritized the deal over others, and the unusually low fee structure raises concerns about whether JPMorgan compromised compliance standards in pursuit of this transaction.
President Trump’s recent America First Investment Policy (NSPM-33) aims to prevent Wall Street from funneling American funds into companies supporting China’s military-industrial complex and human rights abuses. CATL’s IPO represents precisely the type of investment this policy seeks to deter. The memorandum states:
"The United States will establish new rules to stop United States companies and investors from investing in industries that advance the PRC’s national Military-Civil Fusion strategy."
By underwriting this IPO, JPMorgan is exposing itself and American investors to serious regulatory, financial, and reputational risks.
Given CATL’s direct links to China’s military modernization, its complicity in the ongoing genocide in Xinjiang, and the broader risks to U.S. national and economic security, we urge JPMorgan to immediately withdraw from underwriting CATL’s IPO.
If JPMorgan is unwilling to withdraw, we request full and detailed responses to the following questions no later than April XX, 2025:
Requested Information
How does JPMorgan justify financing a company designated by the U.S. Department of Defense as a "Chinese military company" under Section 1260H?
Please provide all materials, correspondence, and records from CATL to JPMorgan related to its 1260H designation and affiliations with sanctioned entities—both before and after the IPO engagement letter.
Provide internal memos, emails, and meeting notes evaluating these risks by JPMorgan’s risk and compliance teams.
Submit all communications between JPMorgan and CATL regarding XPCC, U.S. sanctions, and the Uyghur Forced Labor Prevention Act.
Provide documentation of risk assessments or due diligence related to CATL’s military designation and ties to sanctioned organizations.
Does JPMorgan acknowledge CATL’s designation under Section 1260H and its ties to China’s military-industrial complex?
Does JPMorgan recognize that CATL’s lithium-ion technology is being used to modernize China’s submarine fleet?
How does JPMorgan’s role in underwriting CATL’s IPO align with its stated opposition to autocracy and forced labor?
Has JPMorgan assessed the regulatory and reputational risks of this IPO in light of Congressional scrutiny? What steps were taken to mitigate these risks?
Did JPMorgan consult U.S. government agencies (e.g., Treasury, Commerce, DoD) before proceeding with the IPO?
Does JPMorgan acknowledge its role in facilitating the erosion of American manufacturing by backing a CCP-aligned company?
Was JPMorgan aware of CATL’s military designation before engaging in its IPO? What compliance reviews were conducted?
What disclosures has JPMorgan made to investors regarding CATL’s 1260H designation?
What valuation methodologies did JPMorgan apply? Were geopolitical risks factored into the pricing model?
What marketing strategies are in place? Were any efforts made to exclude U.S. investors due to the 1260H designation?
Has JPMorgan included indemnities or warranties to shield itself from liability due to CATL’s military ties?
Who are the external legal, auditing, or national security advisors JPMorgan used? Have any raised concerns? Will these be disclosed?
Has JPMorgan received communications from Chinese officials or CCP representatives regarding the IPO? Were these reported to U.S. regulators?
Has JPMorgan assessed whether its involvement could trigger obligations under the Foreign Agents Registration Act (FARA)?
Have internal audits or compliance reviews been conducted regarding JPMorgan’s pursuit of the IPO? What were the findings? Was the fee lowered to gain CCP favor?
Were edits made to CATL’s IPO prospectus due to military designations or sanctions concerns? If so, please provide drafts and note the changes.
To deliver your responses or for any related inquiries, please contact the Select Committee majority staff at (202) XXX-XXXX.
The House Select Committee on the Strategic Competition Between the United States and the Chinese Communist Party is authorized under H. Res. 5 Sec. 4(a) to investigate and recommend policy responses to the economic, technological, security, and ideological threats posed by the CCP.
Thank you for your attention to this important matter. We appreciate your prompt and full reply.
Sincerely,
John Moolenaar
Chairman
House Select Committee on the CCP
You can view the PDF of this letter HERE