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美国对外投资限制
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解析美国对外投资限制清单(国金宏观厉梦颖)
雪涛宏观笔记· 2025-04-22 14:28
Core Viewpoint - The "America First Investment Policy" memorandum continues the Trump administration's stance on strengthening foreign investment reviews, focusing on a "differentiated" review mechanism that relaxes investment restrictions from allies while strictly controlling investments from "foreign adversaries" [1][3]. Summary by Sections Investment Policy Framework - The memorandum aims to promote the development of high-tech industries like AI domestically while welcoming investments from allies and partners, provided they align with U.S. interests and benefit the American people [5]. - Investments from allied countries will have a "fast-track" process, facilitating easier access to U.S. technology sectors, but must avoid collaboration with foreign adversaries [5]. Regulatory Measures - The Trump administration has previously issued several executive orders regarding foreign investment restrictions, including Executive Order 13959 and its revision 14032, as well as Biden's 14032 and the recent 14105 [4]. - The policy framework includes various entity lists for investment control, such as NS-CMIC List, SDN List, MEU List, and Entity List, with additional attention to CMC List and UFLPA Entity List [4]. Entity Lists and Their Implications - The NS-CMIC List targets U.S. persons' investments in Chinese military-related companies, with 68 entities listed as of January 2025, primarily in capital goods and technology hardware sectors [9]. - The SDN List includes entities that face asset freezes and transaction bans, with over 600 Chinese entities listed, mainly related to sanctions against Russia and Iran [12][13]. - The Entity List restricts access to sensitive technologies for over 900 Chinese entities, particularly in software, hardware, and semiconductor sectors [17]. - The MEU List is used to control items for military purposes, with 71 Chinese entities listed as of January 2025 [18]. - The CMC List, established by the Department of Defense, includes 134 Chinese entities, primarily in capital goods and technology sectors, with potential future restrictions [21]. - The UFLPA Entity List focuses on products linked to forced labor allegations, with 144 Chinese entities listed, affecting various industries [23]. Future Considerations - The U.S. government may further develop new tools to limit investments in Chinese companies, although successful negotiations between the U.S. and China could render the memorandum less impactful [27].