The U.S. outbound investment regime is live. Since January 2025, it has reshaped how asset managers approach capital deployment into China's high-technology sectors, and the questions it raises show no sign of abating.

AIMA is pleased to present this guide, produced in collaboration with Gibson Dunn & Crutcher. Structured as an FAQ, it addresses the programme's scope, jurisdictional reach, notification requirements, legal and practical standards, and key exceptions, with particular focus on the publicly traded securities exception and its application in the IPO context.

The guide goes beyond the rules themselves. It covers how the U.S. regulator has administered the programme in practice, how markets have responded since inception, and what lies ahead as legislative amendments take shape.

Our aim is to give AIMA members the clarity they need to act with confidence.

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  Kher Sheng Lee

  Managing Director, Co-Head of APAC and Deputy Global Head of Government Affairs, AIMA

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  David A. Wolber

  Registered Foreign Lawyer (New York) of Gibson, Dunn & Crutcher (Hong Kong) and Partner of Gibson, Dunn & Crutcher LLP