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China’s Restricted ODI Investments
China’s Outbound Direct Investment (ODI) regime does not only classify projects as “encouraged” or “prohibited.” A significant middle category exists: Restricted Investments.These projects are not automatically banned—but they are subject to heightened scrutiny and approval requirements, particularly by the:National Development and Reform Commission (NDRC)Ministry of Commerce of the People's Republic of China (MOFCOM)A key feature in many restricted scenarios is whether domestic assets, onshore financing, or guarantees are involved. Projects fully funded overseas may fall outside certain…
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