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China's scrutiny of Meta's proposed $2–$2.5 billion acquisition of Singapore-based AI startup Manus has crystallized a broader strategic shift in its approach to technology exports and cross-border investment. The deal, which involves a company with Chinese origins, has drawn intense regulatory attention from the Ministry of Commerce (MOFCOM) and other agencies, who are investigating whether the transfer of Manus's AI technology and talent
. This case underscores Beijing's growing determination to retain control over advanced technologies, even as it seeks to attract foreign capital through recent financial reforms. For global investors, the episode highlights the dual-edged nature of China's evolving AI landscape: a market brimming with innovation but increasingly constrained by regulatory and geopolitical risks.
The regulatory focus extends beyond technology to talent. Manus's relocation from China to Singapore, coupled with its AI expertise, has raised alarms about the "brain drain" of Chinese-origin innovators.
, such cases could incentivize more startups to shift operations abroad to avoid regulatory oversight. This dynamic complicates Beijing's dual goals of fostering domestic innovation while curbing outflows of critical assets.China's regulatory agenda is increasingly intertwined with strategic risk management. The AI Safety Governance Framework 2.0, released in September 2025, underscores this shift by categorizing AI risks-particularly in chemical, biological, radiological, and nuclear (CBRN) applications-and proposing technical countermeasures
. A Concordia AI report notes that AI safety has been elevated to a national security priority, with the Politburo dedicating a study session to the issue in April 2025 . Chinese scholars have also published over 26 AI safety papers monthly, doubling the previous year's output, reflecting a surge in frontier research on alignment, interpretability, and misuse prevention .For foreign firms, these developments signal a regulatory environment where compliance is not just a legal obligation but a strategic imperative. Leading Chinese AI firms, including Alibaba and Huawei, have signed voluntary "AI Safety Commitments," pledging to implement red teaming and data security measures
. However, transparency remains limited, with companies providing scant details on risk evaluation outcomes . This opacity creates uncertainty for investors, who must weigh the potential of China's AI sector against the risks of regulatory arbitrage and geopolitical friction.While China's 2025 regulatory framework tightens control, it also introduces contradictions. On one hand, the State Administration of Foreign Exchange (SAFE) has eased cross-border investment through reforms such as simplified registration for foreign-invested enterprises and expanded financing options for SMEs
. These measures aim to attract capital to innovation-driven sectors like AI. On the other, restrictive policies-such as localization requirements and equity caps-continue to deter foreign firms. A U.S. State Department report notes that foreign direct investment in China fell by 27.1% in 2024, driven by concerns over intellectual property and data sovereignty .For AI firms with cross-border exposure, the regulatory landscape is particularly treacherous. Foreign SMEs face disproportionate compliance costs, with studies indicating that up to 17% of AI investments are now allocated to regulatory compliance
. These costs, coupled with fragmented global AI regulations, have created barriers to market entry. As highlighted by Intuitive Operations, 26% of SMEs cite regulatory complexity as a major obstacle to expansion in China . Meanwhile, domestic consolidation in AI and semiconductors-driven by "Made in China 2025"-has further marginalized foreign players .For global investors, the key to navigating China's AI sector lies in strategic risk assessment and selective capital reallocation. Opportunities exist in areas aligned with Beijing's priorities, such as AI safety, privacy-preserving technologies, and cloud-native security
. However, these opportunities must be balanced against the risks of regulatory overreach, geopolitical tensions, and capital repatriation constraints.The Meta-Manus case serves as a cautionary tale: even high-profile deals are not immune to Beijing's scrutiny. As China's regulatory apparatus becomes more sophisticated, foreign firms must adopt a dual strategy of compliance and innovation. This includes investing in localized R&D, aligning with domestic standards, and diversifying supply chains to mitigate exposure to regulatory shocks.
In the long term, China's AI ambitions will likely shape global governance frameworks, as seen in its push for initiatives like the Global AI Governance Initiative. For investors, the challenge will be to participate in this evolution without becoming collateral in the broader U.S.-China tech rivalry. The Manus acquisition, whether blocked or approved, is a harbinger of a new era where strategic risk and regulatory agility will define success in China's AI markets.
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