China’s Outbound Investment Regulation Ties Deals to Export Controls, Data Transfers and Countermeasures

China’s new State Council Regulation on Outbound Investment takes effect July 1 and creates a centralized outbound-investment regime with national-security review, export-control limits, cross-border data-transfer constraints and countermeasures provisions. Mayer Brown highlights rules prohibiting indirect transfers of restricted technology or data through means such as overseas relocation of personnel, technical guidance or training. This is a conflict-of-laws problem for multinationals. Legal teams handling China-linked transactions need diligence on technology, data, personnel movement, foreign investigations and counter-sanctions exposure before deal structuring.