在之前的文章中，笔者曾提到过另一家和Manus的境遇有些相似的中国AI企业，HeyGen。 Manus并不是这样做的第一家公司，例如再早之前的HeyGen（中国AI技术人员徐卓创立），总部已经从深圳搬迁至美国洛杉矶。而随着 Reverse CFIUS、CFIUS、14117等一系列美国管制法案与禁令的落地，"选边站"也许会成为越来越多企业所面临的绕不过的问题。（《Manus 被Reverse CFIUS调查之后，"AI套壳"类产品值得关注的X个问题》） 细究之下，会发现HeyGen和Manus的共同之处比想象中更多——同样是中国出身的创始人、同样投身于AI赛道、相似的市场销售路径（锚定海外市 场）、同样的早期股权架构（VIE架构）、相似的早期投资人（红杉与真格基金）、同样是由Benchmark领投一轮估值高达5亿美元的融资。 然而，命运却给了它们截然不同的剧本：HeyGen 风生水起，服务全球85，000家企业，年收入暴涨；而 Manus 却因美国财政部的 Reverse CFIUS 调查而 颇有一些进退维谷。 为何曾经如此相似的两家公司，如今却如此同命不同运？ 一、HeyGen：从中国深圳到美国独角兽 由于 ...

Core Viewpoint - The ongoing investigation into Manus by U.S. regulatory authorities regarding its recent financing raises significant concerns for Chinese AI companies and investors, particularly in light of the Reverse CFIUS regulations that restrict U.S. capital and high-end technology from flowing into critical sectors in China [1][2][4]. Group 1: Manus Financing and Regulatory Scrutiny - Manus completed a new round of financing led by Benchmark, achieving a valuation of $500 million (approximately 3.6 billion RMB) [4]. - Following this financing, Manus underwent several business registration changes, suggesting the deal was successfully closed [4]. - The company is currently under investigation by U.S. regulators due to its acceptance of investment from a U.S. firm, which may violate Reverse CFIUS regulations [4][5]. Group 2: Reverse CFIUS Regulations - The Reverse CFIUS regulations, effective January 2, 2025, specifically target investments in AI, semiconductors, and quantum information technology from U.S. entities into China [4]. - The regulations set a threshold for what constitutes "restricted activities," focusing on whether a business like Manus engages in "covered activities" that meet these criteria [5][6]. - Two key conditions must be met for a business to fall under the Reverse CFIUS regulations: whether the business has "designed" or "substantially modified" its AI models and whether its training computation exceeds 10^23 [7][11]. Group 3: Implications for Other Companies - The outcome of Manus's case will serve as a critical observation point for other Chinese AI companies and investors, especially as more firms begin to file for Reverse CFIUS exemptions [2][15]. - If Manus is deemed to have merely "called" upon existing AI models without substantial development, it may avoid regulatory penalties; however, if its activities are classified as "development," it could face significant scrutiny [7][8]. - The potential for increased regulatory oversight may compel companies to invest more resources in compliance, leading to strategic adjustments in their operations and corporate structures [14][15]. Group 4: Strategic Adjustments and Market Trends - Companies are beginning to consider separating their U.S. and Chinese operations to navigate the complexities of multiple regulatory frameworks, including Reverse CFIUS and EO 14117 [14][15]. - Manus has reportedly moved its headquarters to Singapore and is optimizing its workforce in China, indicating a shift towards compliance with international regulations [14][15]. - Other companies, such as HeyGen, have also relocated their headquarters to the U.S. in response to similar regulatory pressures, highlighting a trend of "choosing sides" in the current geopolitical landscape [15].