外国投资监测

November 2025 ForeignInvestment Contents Executive summary 1.The full circuit: FDI and national security in theelectric-vehicle era National security has become thedominant lens for global investment.Sectors that governments once activelycourted for foreign investment due toits economic benefits – from data and EVs now sit at the intersection of technology, infrastructure and data security– making them a new focal point for investment scrutiny 2.The rise of golden shares: A new layer to FDI screening? From US Steel and Doliprane to Royal Mail, governments are reviving golden sharesto retain control over strategic assets – signaling a broader move toward state 3.Balancing security and growth: Investment screening underthe UK’s Modern Industrial Strategy This edition ofForeign InvestmentMonitorexamines how FDI policy isadapting as industrial strategy,geopolitics and economic resilience The UK aims to simplify its regime while tightening control of critical sectors, fromsemiconductors to water. 4.Navigating the new landscape: The EU’s Foreign SubsidiesRegulation and its merger tool The FSR’s reach is testing how Europe can safeguard fair competition withoutdeterring capital – a pivotal moment for cross-border M&A. 5.After the mitigation boom: The case for ending zombieCFIUS agreements Hundreds of outdated national security agreements continue to burden investors.New regulatory powers offer a rare chance to streamline obligations and refocus 6.Europe oversees the tightening of its FDI net, but unityremains elusive The EU’s screening framework is expanding fast but remains fragmented, asBrussels seeks coordination while Member States guard sovereignty. Freshfields also co-edited Lexology’sIn Depth: Foreign Investment Regulation, which explores the same global shift towardsecurity-driven investment policy. The full circuit: FDI andnational security in theelectric-vehicle era negotiations with the United States,subsequently suspending the controlsas part of such negotiations. Thesemoves underscore the fragility of global In brief Every stage of the EVvalue chain, frommaterials throughproduction to data-richoperation, is viewed as Electric vehicles (EVs) – includingdriverless models – bring togetherrare earth materials, advancedengineering and connectedsoftware in systems thatgovernments now view as criticalto both competitiveness andsecurity. Every stage of the EVvalue chain, from materialsthrough production to data-rich This importance has beeninstitutionalized by governments ininvestment policy through multiplemechanisms. President Biden's 2022Executive Order on the Committee onForeign Investment in the United States(CFIUS) directed CFIUS to scrutinize Critical minerals: Supplychains under pressure EVs begin with geology and chemistry.Lithium, nickel, cobalt, graphite andrare earths not only determine prices,they expose supply vulnerabilities.FDI authorities focus on control anddenial of access. Concentration ofmining and refining capacity in a handfulof jurisdictions generates classicleverage risks – export restrictions, Production: Where clean techmeets hard power The middle of the EV value chain – fromR&D and component manufacturing tofinal assembly – brings dual-usetechnology concerns to the fore.Wide-bandgap silicon-carbide powermodules used in EV inverters can alsoharden radar and directed-energysystems against thermal stress.High-density battery-management China recently wielded its dominance inrare earth materials – and their criticalrole across defense, semiconductor,auto, and “clean” energy sectors – as ageopolitical instrument against theUnited States. Throughout 2025, therehas been a complex interplay betweenescalating Western restrictions on The full circuit: FDI and nationalsecurity in the electric-vehicle era In the US, a 2024 battery plant project inMichigan backed by Chinese companyGotiondrew congressional attentionafter CFIUS determined it lackedjurisdiction to review because theproject was a greenfield investmentoutside its real-estate authority. Thecontroversy prompted the addition ofthe nearby Camp Grayling militaryinstallation to the list of “extended charging authentication systems arealso technically feasible where vehiclesshare a common vulnerable supplier orplatform. Concentrated in dense urbanareas with high EV adoption, such sensor platforms transmitting location,usage and diagnostics data, along withcontinuous over-the-air updates. Suchdata has intelligence value: it can reveal A consortium that included Chineseinvestorsreportedlyabandoned aplanned minority investment inautomotive-mapping company afterencountering CFIUS concerns – anexample of how data exposures alonecan derail a deal. Across other The EV value chaintouches nearly everycategory of nationalsecurity risk that FDIauthorities monitor –from critical mineral In China, the EV sector has been astrategic pillar of national economicpolicy for years. A foreign investor’sacquisition of control