; sale; security The terms purchase , sale , and security have the meanings given those terms in section 3(a) of the Securities Exchange Act of 1934 ( 15 U.S.C. 78c(a) ). (9) U.S. person The term U.S. person has the meaning given the term in section 120.62 of title 22, Code of Federal Regulations, or any successor regulation. (10) Willfully The term willfully , with respect to an action, means that the action is taken voluntarily and intentionally in violation of a known legal duty. (b) Prohibition (1) In general Except for the purposes of complying with paragraph (2), beginning on the date of enactment of this Act, it shall be unlawful for any U.S. person to make use of the mails or any means or instrumentality of commerce to engage in a covered transaction with respect to a covered security. (2) Divestment required Not later than 180 days after the date of enactment of this Act, each U.S. person shall divest of all covered securities held by the U.S. person. (c) Penalties A U.S. person that violates, attempts to violate, conspires to violate, or causes a violation of this section shall be subject to any of the following penalties: (1) A civil penalty in an amount not to exceed the greater of— (A) $350,000