On July 8, 2026, JunHe partner Kenneth ZHOU spoke at a seminar hosted by the American Chamber of Commerce in Beijing, titled Understanding the State Council Regulations on Outbound Investment (State Council Decree No. 837). Mr. Zhou is a former board member and general counsel of AmCham China and is the current co-chair of its Outbound Investment Committee. He delivered a presentation entitled Understanding China’s New Outbound Investment Regime and the Blocked Meta-Manus Deal Amid U.S.-China Geopolitical Competition.
In his remarks, Mr. Zhou provided an in-depth analysis of the Regulations of the State Council on Outbound Investment, which officially took effect on July 1, 2026. He noted that the new regulations mark a shift in China’s outbound investment regulatory framework from a previously fragmented approach to a more systematic and unified top-level legal design, creating a clearer and more comprehensive framework for outbound investments by enterprises, organizations and individuals.
Drawing on the high-profile blocked Meta-Manus transaction, Mr. Zhou focused on the policy considerations underlying the new rules. He observed that a central trend in the current regulatory environment is that ‘substance prevails over form’. Regardless of how a transaction is structured, any arrangement involving the transfer of artificial intelligence or other sensitive technologies, core data, or key technical personnel may trigger a stringent national security review. Mr. Zhou cautioned that cross-border transactions involving sensitive sectors, national security, technology security, industrial policy and geopolitical considerations must be treated as core decision-making factors, and that traditional offshore restructuring may no longer be an effective means of avoiding regulatory risk.
Mr. Zhou also discussed the mechanisms of a ‘Board of Trade’ and a ‘Board of Investment’ following the recent Xi-Trump summit. He noted that although channels for dialogue between China and the United States may continue to expand, the broader trend toward tighter investment scrutiny in strategic technology sectors is unlikely to change fundamentally.
Mr. Zhou is a corporate lawyer dual-qualified in the United States and China. He has nearly 30 years of experience advising on cross-border investment, mergers and acquisitions and regulatory compliance matters. His practice focuses on foreign direct investment, cross-border M&A, complex commercial transactions, government regulation and compliance, as well as cybersecurity and data protection. Mr. Zhou authored the chapter on company law in China Business Law published by the International Chamber of Commerce, and the investment policy chapter in AmCham China’s Annual White Paper. Drawing on extensive practical experience and strong academic insight, Mr. Zhou has been interviewed by leading Chinese and international media outlets including CCTV, CNN and Bloomberg, and has spoken at a wide range of industry forums regarding cross-border investment, financing and complex regulatory compliance matters.
