Laura Black

Key Points Treasury has issued a Final Rule to implement President Biden’s 2023 EO targeting U.S. investments in Chinese companies engaged in certain activities related to semiconductors, quantum computing or AI. Once the Final Rule becomes effective on January 2, 2025, U.S. persons will be prohibited from engaging in certain transactions in these sectors involving China or Chinese persons, while others will require a notification to the U.S. government. The focus is on equity investments, though some debt financing as well as greenfield, brownfield and joint venture-related investments will be covered. The rules squarely apply to private equity and venture capital funds with a U.S. general partner.