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Outbound Foreign Investment Reviews
What does China’s block of Manus deal mean for outbound regime?

What does China’s block of Manus deal mean for outbound regime?

As we reported last week, China has blocked Meta’s $2 billion bid for Manus AI, a Singapore-based company founded in China in 2022. According to experts, the move raises a number of questions about the Outbound Investment Security Program, and the updated rule that will drop in 2027.

AstraZeneca-Shanghai “outbound” deal announced … but only in China

AstraZeneca-Shanghai “outbound” deal announced … but only in China

Last week, UK-based biopharma AstraZeneca announced it would make a major investment in cell manufacturing and supply in Shanghai. The Chinese-language announcement, which was curiously not made available in English or released in the UK or U.S., creates yet another “outbound” case study.

Lawmakers want management consulting, biotech in outbound

Lawmakers want management consulting, biotech in outbound

As we reported at the end of last year, new outbound investment restrictions have officially been enshrined in the 2026 National Defense Authorization Act. Now a group of Congressional leaders is urging Treasury Secretary Scott Bessent to consider additional steps. Details inside.

How does the NDAA version of outbound differ from the OISP?

How does the NDAA version of outbound differ from the OISP?

As we reported last week, new outbound investment restrictions have officially been enshrined in the 2026 National Defense Authorization Act. But how do the changes differ from the Treasury Department’s Outbound Investment Security Program? Details inside.

Outbound foreign investment restrictions get included in NDAA

Outbound foreign investment restrictions get included in NDAA

House and Senate leaders have finalized wording that would embed outbound investment restrictions in the 2026 National Defense Authorization Act conference report; we noted in October that this was likely. But some experts say the move may now conflict with the Administration’s position on China.

Outbound review is six months late, and Senators want to know why

Outbound review is six months late, and Senators want to know why

Five U.S. Senators have written a letter to Treasury Secretary Scott Bessent requesting a detailed update on the outbound investment screening program. A Presidentially ordered review of the program, complete with recommendations for changes, was due on April 1, and the Senators want answers.

Senate passes bipartisan outbound amendment to NDAA for FY2026

Senate passes bipartisan outbound amendment to NDAA for FY2026

Last week, the Senate passed an amendment to the fiscal year 2026 National Defense Authorization Act that addresses outbound investments in China and other matters. The bill, which we covered back in March, is one of many efforts to strengthen and enshrine the outbound investment security program.

Arkansas is the latest state to ban investing in Chinese companies 

Arkansas is the latest state to ban investing in Chinese companies 

A law in the state of Arkansas, which becomes effective this week, would force state investment entities to divest from China, and would ban future investment there. The move follows similar outbound investment proposals in Florida, South Dakota, Indiana, and others. Details, context inside.

Trump to review outbound regime, export controls, ICTS rules, more

Trump to review outbound regime, export controls, ICTS rules, more

The Outbound Investment Security Program is now effective, but don’t get too attached to it. According to a Presidential trade memorandum released in January, the Trump administration is now reviewing the outbound regime and other policies to determine whether they should be “modified or rescinded.”

Outbound investments dating back to 2021 are getting reviewed in EU

Outbound investments dating back to 2021 are getting reviewed in EU

Last week, the European Commission urged its member states to scrutinize outbound investments in non-EU countries, and to do so for the same technologies impacted by the U.S. outbound regime: semiconductors, quantum and AI. Details and related EU documents are inside.

Templates, guidance on outbound program (now effective) get posted

Templates, guidance on outbound program (now effective) get posted

Right before the holidays, the Treasury Department published answers to thirty questions about the outbound investment security program. The document provides helpful examples of covered transactions, and was supplemented by a number of notification templates. Details, documents inside.

We get a sneak peek at next week’s Outbound event; but register now…

We get a sneak peek at next week’s Outbound event; but register now…

Right before Thanksgiving, we learned what was on the agenda for Treasury’s Outbound conference on December 9. According to Treasury officials, the half-day event will be heavy on discussions about operationalization and implementation, with lots of Q&A. Sounds good, but registration closes soon…

Expert: Use tax abatements to get U.S. investment capital out of China

Expert: Use tax abatements to get U.S. investment capital out of China

An expert on national security has proposed an alternative to an outbound foreign investment review regime: Offer tax abatements to U.S. capital in China that repatriates to the U.S. and deploys elsewhere. The tax incentives would be tied to foreign policy and national security goals.

Outbound rule has been submitted to OMB; heading to final stages?

Outbound rule has been submitted to OMB; heading to final stages?

According to publicly available data confirmed by industry experts, the Treasury Department’s outbound investment proposal has been filed with the Office and Management and Budget. That means the proposed rule is likely in its final stages, and could be published soon. More inside.

At hearing, experts back sanctions, entity-based approach to outbound

At hearing, experts back sanctions, entity-based approach to outbound

At a House Financial Services Committee hearing on outbound, experts stated that Biden’s E.O. would create a “cumbersome and unnecessary bureaucratic process,” and that outbound investment authorities “should not be located within CFIUS.” Details, insights, and copies of the testimony are inside.

China Select Committee wants more broad approach to outbound regime

China Select Committee wants more broad approach to outbound regime

Leaders of The Select Committee on the Chinese Communist Party have offered Treasury Secretary Janet Yellen implementation recommendations on the outbound Executive Order. Experts say it represents a broader or “maximalist” approach to regulating outbound investment. Details inside.

Many VCs may be underestimating the full impact of outbound rule

Many VCs may be underestimating the full impact of outbound rule

The vast majority of venture capital firms say they will not be impacted much by the Treasury’s proposed rule on outbound investment. That’s according to our latest survey; only 16 percent of respondents said they would be impacted “significantly” by the proposal. Details inside.

Experts say outbound rule could impact investments in the U.S.

Experts say outbound rule could impact investments in the U.S.

Much has been made of the fact that the Treasury Department’s proposed rule focuses exclusively on China. But that’s not the full story. In fact, the proposal could impact investments in any country, even the U.S., under certain circumstances. Details, examples of possible scenarios, and insights inside.

Clock ticking on effective date for some provisions of outbound rule

Clock ticking on effective date for some provisions of outbound rule

Okay, let’s not beat a dead horse. The E.O. has been released, and Treasury is seeking comment on their implementing rule, which likely won’t be finalized until next year. We know. But experts clarify that some of the provisions may be effective immediately. Details and insights are inside.

Treasury already seeking comments on the outbound investment regime

Treasury already seeking comments on the outbound investment regime

Just a few hours after President Biden issued the Executive Order on outbound investment in China, the Treasury Department unveiled its “Advanced Notice of Proposed Rulemaking,” and began soliciting feedback. Details, key questions, and instructions for commenting are inside.