The Mechanism: How NDRC Built a 'Chinese CFIUS' on the Fly
The block was not delivered through China's traditional anti-monopoly review track. It came from the NDRC's Office of the Working Mechanism for Foreign Investment Security Review, with MOFCOM acting as the front-end probe arm starting January 2026. According to research, MOFCOM stated it would assess 'compliance with export controls, technology transfer rules, and outbound investment regulations' — what Geopolitechs called 'a deliberately broad framework.' That breadth is the point. Regulators argued Manus's core AI algorithms qualify as restricted export technologies and that its products process massive Chinese user data, requiring technology export licensing and data security assessments the parties allegedly bypassed. In effect, Beijing has stitched together export-control law, data-security law, and outbound-investment rules into a single instrument that functions like a Chinese mirror of CFIUS — only pointed outward at deals leaving the country rather than inward at deals entering it. The legal basis is plural and overlapping by design, which makes it hard for any future cross-border AI deal involving Chinese-origin technology to argue that it falls outside Beijing's reach.



