"In order to confirm that a transaction is out of scope, it will require significant due diligence undertaken by US investors," says Robert A. Friedman, an international trade lawyer.
The outbound investment restrictions are set to take effect on January 2, and in the meantime, the Treasury Department has signaled that some small changes are still on the way to further clarify the rules.
The biggest uncertainty now, as with most parts of the US federal government, is how a second Trump presidency might change things.
Officials also said they're making efforts to coordinate with US allies, like the G7 countries, to introduce similar measures that would prevent Chinese AI companies from turning to VCs in Europe, Canada, or Japan.
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