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中国AI项目拿了美元资本,如何避开美国安全审查?
阿尔法工场研究院·2025-05-27 10:15

Core Viewpoint - Investors and companies need to understand Reverse CFIUS regulations to assess potential compliance risks during investments or financing activities, ensuring proper agreements are made to protect their interests [1]. Group 1: Reverse CFIUS Overview - The article discusses the implications of Reverse CFIUS on investments in Chinese AI companies, particularly focusing on the case of "Butterfly Effect" and its recent funding from Benchmark [1][2]. - Reverse CFIUS is concerned with four fundamental elements: "U.S. entity," "restricted entity," "restricted business," and "restricted transaction" [2]. Group 2: Key Factors in Manus Case - The nationality of the founder is crucial; if the founder is recognized as a "U.S. entity," it may impose restrictions on their ownership of a Chinese AI company [4][6]. - The company's ownership structure and the primary revenue sources are also significant in determining if it qualifies as a "restricted entity" [6][7]. Group 3: Business Operations and Revenue Sources - If the founder is a Chinese national without a U.S. green card, they would not be subject to Reverse CFIUS jurisdiction [5]. - The analysis indicates that "Butterfly Effect" may not meet the "deep dependency" requirement, as its primary revenue likely comes from overseas entities rather than domestic operations [9]. Group 4: Restricted Business Assessment - The article highlights that not all AI businesses automatically fall under "restricted business" categories; the threshold for computational power is set at 10^23 operations [13]. - "Butterfly Effect" may not meet this threshold, suggesting that its operations might not be classified as "restricted business," thus reducing the likelihood of Reverse CFIUS implications [15]. Group 5: Conclusion and Considerations - The findings suggest that while "Butterfly Effect" could be considered a "restricted entity," its main business may not be classified as "restricted," allowing for potential investment without triggering Reverse CFIUS [15]. - The article raises additional questions regarding the implications if the founder were a U.S. citizen or if the company primarily served the domestic market [15].