CFIS 24: Paris Insights – Preserving the Battlefield Gap in the Area of Technology: Between Export Control and Outbound Investment Screening 

A. The Battlefield: Preserving the Technological Gap

The advent of 7nm semiconductor production represents a monumental leap in chip manufacturing technology, delivering a 10-15% performance boost over 10nm chips and an impressive 25-30% improvement compared to 14nm counterparts.[i] Introduced in 2019 by the South Korean tech giant Samsung Electronics and Taipei-based chip manufacturing pioneer Taiwan Semiconductor Manufacturing Company (TSMC), 7nm semiconductors allow to create products with higher performance, higher power efficiency, and more compact form factors.[ii] This groundbreaking advancement elevates electronic hardware to unprecedented levels, revolutionizing civilian and military spaces and thus redefine the geopolitical relevance of controlling this technology.[iii]

Amidst the growing US-China trade and technology confrontation, China-based Semiconductor Manufacturing International Corporation (SMIC) announced in August 2022 its breakthrough in manufacturing 7nm semiconductors on Chinese soil—an achievement the US government sought to prevent through restricting the export of cutting edge semiconductors and its manufacturing equipment.[iv]  While the U.S. denounces the quality of China’s domestically produced chips, with U.S. Commerce Secretary Gina Raimondo asserting that “the export controls are working because that chip is not nearly as good (…) it’s years behind what we have in the United States,” SMIC breakthrough signifies China’s ambitions in the race for technological leadership in line with its Made In China 2025 industrial policy.[v] Efforts to gain and maintain a technological and competitive advantage of emerging technologies have only just begun and are accelerating rapidly.

Amid a race for technological leadership the motives of imposing export controls and restrictions have evolved from preventing the proliferation of weapons of mass destruction towards maintaining relatively broad notions of economic and national security. Established as central economic security policy instrument and applied in tandem with industrial policy and foreign investment screening, export controls of critical emerging technologies pose unprecedented challenges to governments and regulatory authorities in balancing market openness, competitiveness, and private business interests with essential security interests.

This background paper sets out to explore and to contextualize export controls within the landscape of economic security policies featured by national industrial strategies and considerations of outbound investment screening. Firstly, the background paper considers the characteristics of advanced semiconductors as the most contested emerging technology in race for leadership as a case in point. Secondly, the background paper elaborates on the economic and political challenges of export controls and outbound investment screening. Thirdly, a closer perspective on the issues facing the European Union is provided. Fourthly, the background paper outlines contemporary strategic considerations.

B. Emerging Technologies: Semiconductors

While semiconductors and advanced microelectronics dominate the forefront of technological rivalry,[vi] the contest for supremacy extends beyond these domains, with quantum computing, artificial intelligence, biotechnology, and green technologies intensifying the race for global leadership.[vii] What makes semiconductors a particular case in point is that they are essential for all different above-mentioned technologies, their wide range of applications, the import dependency of Western countries, and their complex global supply chain.[viii]

The wide spectrum of application is exemplified by the US’s dependence on semiconductors in its civilian and military economy. Semiconductors are crucial for most weapon systems acquired by the U.S. Pentagon, such as hypersonic weapons and advanced telecommunication systems.[ix] Moreover, semiconductors constitute the largest share of all US electronic product exports, demonstrating their vital role for the nation’s welfare.[x] Being a key resource for all other emerging technologies such as AI, Quantum Computing and Biotechnologies, semiconductors dominate economic and military security considerations of governments in the 21st century.

In particular, the growing dependency of the US and the EU on Taiwanese chip imports, which increasingly hinge on Taipei’s sovereignty, has prompted the tightening of export controls and the introduction of industrial policies aimed at strengthening Western, i.e., domestic semiconductor manufacturing capacities to accommodate national security objectives. The Covid-19 Pandemic and Russia’s full-scale invasion of Ukraine have served as an additional catalyst for advancing domestic manufacturing capacities to strengthen supply chain resilience in times of geopolitical tension and conflict.[xi]

In the US, The CHIPS and Science Act[xii], enacted by the Biden Administration in 2022, has allocated $280 billion to strengthen US semiconductor capabilities, advance research and development, and create regional technology hubs.[xiii] Moreover, the Act incorporates a guardrails — provisions designed to prevent the allocation of funds to businesses that could present national security threats. Notably, those businesses receiving CHIPS funding are barred from undertaking “significant transactions” that would extend chip manufacturing capabilities to nations deemed “problematic”, such as China.[xiv] In a similar spirit, the EU Commission passed its European Chips Act[xv] in 2023 aiming to mobilize  “€43 billion of public and private investments and set measures to prepare, anticipate and swiftly respond to any future supply chain disruptions, together with Member States and international partners.”[xvi] Recognizing their shared vulnerabilities and interdependencies, both Washington and Brussels have made collaboration essential, allowing EU-based semiconductor firms to be eligible for funding under the U.S. CHIPS Act and U.S.-based firms to receive support from the EU Chips Act.[xvii]

The highly complex and globalized semiconductor ecosystem and supply chain pose significant challenges for the US and the EU in achieving autonomy in semiconductor production, particularly with respect to the final step in the supply chain assembly, testing, and packaging (ATP). Taiwan dominates this stage, accounting for 90% of global chip production, largely due to its national flagship company, TSMC, which specializes in this critical industrial activity and possesses the necessary human skill and facilities. While both the US and the EU account for only 10% of ATP activities, they still represent critical choke points in the semiconductor supply chain, particularly in research and development (R&D) intensive areas essential for chip design and manufacturing equipment.[xviii] With the majority of the world’s semiconductor design engineers located in the US,[xix] excelling in both chip design and software, the US stands as a critical hub for the most resource-intensive and pivotal R&D phase of the semiconductor supply chain.[xx] With remarkable 72% of global chip design software and license sales, the US disposes over significant intellectual property rights within its borders, providing an industrial competitive advantage.[xxi]

In Europe, semiconductor manufacturing equipment is heavily concentrated in the Netherlands, with Advanced Semiconductor Materials Lithography (ASML) as the worlds single producer in manufacturing extreme ultraviolet (EUV) lithography equipment for creating cutting-edge chip technology at the 7nm level or below.[xxii] The colossal machine, essential for advanced semiconductor manufacturing, relies heavily on German engineering. A high-power CO2 laser from TRUMPF and precision optics from Carl Zeiss, both German innovations, enable the nanometer-level accuracy required by ASML to produce next generation chips.[xxiii] While ASML leads in EUV technology, Japanese giants Nikon and Canon, alongside ASML, dominate the market for less powerful deep ultraviolet (DUV) machines, which are essential for producing chips at the 14nm scale. Consequently, the highly globalized and fragmented semiconductor value chain necessitates coordinated multilateral cooperation, which, however, presents several economic and political challenges to developing coherent export control approaches.

I. Challenges to Export Controls: Political Fall-Out, Economic Prosperity, Multilateralism and Political Challenges

As a response to China’s breakthrough in developing 7nm chip technology in 2022, the U.S. imposed restrictions on the export of advanced chips and chipmaking equipment to China and urged its allies with vital choke points in the semiconductor value chain to follow suit.[xxiv] As a result, Japan, home to chip equipment manufacturers Nikon, Canon, Tokyo Electron, and others implemented export controls in July 2023 on 23 types of equipment, ranging from film deposition machines to etching devices. Subsequently, the Dutch government introduced a licensing requirement for ASML’s DUV semiconductor equipment prompting the company to announce that Chinese customers would not receive its most advanced machines starting January 1, 2024.[xxv] Although Japan and the Netherlands initially supported the U.S. initiative, they approached the push to tighten export controls against China with caution. Both administrations were wary of potential economic and diplomatic fallout, fearing entanglement in the escalating confrontation between Washington and Beijing.[xxvi]

II. Economic Implications

The negative economic impact of export restrictions on the semiconductor industry can be categorized into three main points: a loss of revenue, a decrease in stock market capitalization, and adverse reactions from the targeted government towards the industries of the country imposing export restrictions.[xxvii] From an economic perspective, Dutch chip manufacturer ASML indicated that imposed export restrictions would impact an estimated 5% share of the companies group sales[xxviii]; a fortune, considering the semiconductor industry as being highly competitive, with massive R&D investments and capital required to keep up pace.[xxix] As a result, the loss of revenue dampens investors’ risk appetite and erodes the investment climate in global financial markets, leading to reduced private capital flows for the affected companies that is essential to advance technologically.[xxx]

As the ongoing U.S.-China economic confrontation has repeatedly shown, the imposition of export restrictions is likely to provoke a reciprocal response. This has been felt by US companies in two ways. Firstly, China’s response to U.S. export controls has included retaliatory measures against U.S. companies, such as banning Micron Technology’s memory chips and blocking Intel’s merger with Tower Semiconductor. Secondly, tightened US controls have accelerated China’s push to strengthen its domestic semiconductor industry through substantial state investment and policy support.[xxxi] Lastly, the tightening of export controls of the home country, arguably, poses a significant threat to the long-term competitiveness of the domestic semiconductor industry vis-á-vis foreign competitors.

C. Multilateralism and Export Controls: The EU Deadlock

While coordination among the U.S., Japan, and the Netherlands underscores the diplomatic obstacles of implementing export controls collaboratively, the EU faces these challenges on an unprecedented scale as it seeks to align action across its 27 member states. In particular, the duality within EU primary law concerning the division of competences on export controls poses a significant challenge to establishing a coherent approach. While export controls of dual-use items are formally classified under the Common Commercial Policy and thus fall within the EU’s exclusive competence, member states retain the ultimate authority over matters related to their national security, as stipulated under Art. 4(2) TEU.[xxxii] Consequently, member states, to a significant degree, have the final say over the scope of export controls at their national borders.

The adoption of the EU Dual-Use Regulation of 2021 has not only highlighted the institutional challenges to streamline export controls among its member states but also revealed the EU’s limited flexibility in responding to shifting geopolitical landscapes and evolving security objectives. This limitation is particularly evident within the framework of existing multilateral export control regimes, which primarily focus on constraining the dissemination of military technology.

While the EU does not dispose over a legal provision to adopt uniform export controls, except in limited areas, the Dual-Use Regulation is bound by control lists of multilateral regimes.[xxxiii] The core issue within these arrangements is that reforms to export control lists require unanimous decision making, enabling Russia to use its veto power as a political leverage. This has repeatedly been demonstrated such as by Moscow’s blocking of key controls on emerging technologies within the Wassenaar Arrangement.[xxxiv] As a result, the blockage by Russia of multilateral regimes has prompted EU member states to enact unilateral export controls, thus heightening the risk of fragmentation within the Single Market and diminish the overall effectiveness of the multilateral export control system in time of geopolitical tensions.

While the EU Commission has witnessed an increasing patchwork of export control lists “due to expansive national security considerations and (or) with the aim to address new risks posed by emerging technologies”, the Dual-Use Regulation allows for coordination and information sharing between member states through so-called national control lists.[xxxv] According to the Regulation, Member States have the option to impose export authorization requirements for dual-use items based on the national control lists of other Member States, especially if there are concerns about public security or human rights.[xxxvi] The main issue is that the adoption of these control lists remains voluntary and depends on extensive information sharing, transparency and consultation on which items bear heightened risks to national and European Security. Consequently, a core risk of a fragmented EU export control system is forum shopping,[xxxvii]allowing potential adversaries to opt the most favorable jurisdiction or regulatory environment in the Single Market to access critical emerging technologies essential to strengthen military capabilities.

D. Complementing Industrial Policy and Export Controls: Outbound Investment Screening

The limited ability of export control regimes to prevent the outflow of emerging technologies or know-how through financial integration has intensified considerations of outbound investment in the US and the EU.[xxxviii] Currently, China, Taiwan, Japan and South Korea dispose over outbound investment screening instruments.[xxxix]

On August 9, 2023, US President Joe Biden signed an executive order aimed at regulating specific categories of US outbound investment in the semiconductor, microelectronics, quantum information technologies, and artificial intelligence sectors. This measure targets investments in “countries of concern” that could pose a risk to US national security.[xl]

In broad line with the US’s Executive Order and its Economic Security Strategy of 2023[xli], The EU’s initial considerations regarding outbound investment screening focus also on mitigating the risk of strengthening military and intelligence capabilities of systemic rivals through European capital flows into a narrow set of “advanced technologies”[xlii] –  namely advanced semiconductors, artificial intelligence, quantum technologies and biotechnologies. Crucially, China remains the primary country of concern due to its civil-military fusion doctrine, which blurs the lines between the commercial and civilian spheres and its military and defense industrial sectors.[xliii]

In the European Union, export controls already partially address outbound investments related to military or dual-use concerns, sanctions, terrorist financing, and money laundering. European companies must obtain a license if their outbound investment involves exporting tangible or intangible goods or services to a Chinese company operating in sectors subject to export controls, such as military or dual-use areas. However, these controls do not apply to investments by European companies in Chinese firms engaged in producing technology with potential military applications or that could be used to violate human rights, particularly when the investment does not involve the export of goods or services.[xliv] In the context of outbound capital flows, the EU Commission identified a significant knowledge gap regarding the national security risks of outbound investments, as the information currently collected by some national authorities, such as central banks and statistical offices, is neither detailed nor specific enough to assess potential security risks accurately. This lack of information hinders the ability of member states and the Commission to conduct proper risk assessments and thus to elaborate on the effectiveness of additional measures screening outbound investments.[xlv]

The introduction of outbound investment screening undoubtedly widens the scope of national security controls over investments that have traditionally been perceived as purely economic. This broadening of the notion of national security is most likely to result in increased compliance cost and uncertainty for European and US companies investing abroad.[xlvi] Moreover, firms subject to outbound investment screening may find themselves at a competitive disadvantage compared to global counterparts not constrained by similar Regulations, potentially limiting their ability to pursue growth opportunities in key markets, particularly in regions like China.

E. Conclusion and Strategic Considerations

Preserving the technological gap in civilian and military spaces has posed unprecedented challenges to national governments in balancing market openness with export controls and investment screening. From a firm’s perspective, the tightening of economic security policy implies the risk of financial loss, which inherently impacts their capacity to reinvest in advancing their technological edge in the future. Moreover, retaliatory measures of targeted countries vis-à-vis the industrial base of the imposing country further impede the firm’s competitive ecosystem and ability to expand to new markets. On a macro level, export restrictions and outbound investment screening bear the risk that targeted countries choose to bolster their domestic industrial base with cash injections, ultimately threatening the long-term competitiveness and technological edge of the imposing economy. From a policy perspective, there are challenges in managing export controls across various jurisdictions in the context of a highly globalised economy with multiple choke points in the supply chain, as exemplified by the semiconductor industry. The ecosystem of emerging technologies, with their military and economic significance, requires “like-minded” nations to coordinate a coherent response to addressing shared vulnerabilities. Therein, national governments should be wary of broadening the scope of national security and securitizing technologies or items with “lower” national security significance, lest they starve their domestic economies of revenue streams. As Frederick the Great said, “He who defends everything, defends nothing.”

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[i] FPT Semiconductor, JSC. 2024. “The ongoing miniaturization race in the semiconductor chip technology: 14nm, 10nm, 7nm, 5nm, 3nm, 2nm.” July 13, 2024. https://fpt-semiconductor.com/technology/.

[ii] Ibid.

[iii] Eurasia Group. 2020. “The Geopolitics of Semiconductors.” https ://www. Eurasiagroup.net/files /upload/Geopolitics-Semiconductors.pdf.

[iv] CSIS. 2023. "Balancing the Ledger on Export Controls: U.S. Chip Technology & China." Center for Strategic and International Studies (CSIS). August 24, 2023. https://www.csis.org/analysis/balancing-ledger-export-controls-us-chip-technology-china.

[v] Financial, Asia. 2024. “Huawei’s China-Made 7nm Chip ‘Years Behind US’, Raimondo Says.” Asia Financial. April 22, 2024. https://www.asiafinancial.com/huaweis-china-made-7nm-chip-years-behind-us-raimondo-says.

[vi] Lewis, James Andrew. 2023. “The End of Export Controls.” September 28, 2023. https://www.csis.org/analysis/end-export-controls.

[vii] Reinsch, William, Thibault Denamiel, Matthew Schleich, and CSIS. 2024. “Optimizing U.S. Export Controls for Critical and Emerging Technologies.” A Report of the CSIS Scholl Chair in International Business. https://csis-website-prod.s3.amazonaws.com/s3fs-public/2024

[viii] Ibid.

[ix] The White House. 2022. “FACT SHEET: CHIPS and Science Act Will Lower Costs, Create Jobs, Strengthen Supply Chains, and Counter China.” The White House. August 9, 2022. https://www.whitehouse.gov/briefing-room/statements-releases/2022/08/09/fact-sheet-chips-and-science-act-will-lower-costs-create-jobs-strengthen-supply-chains-and-counter-china/.

[x] Reinsch, William, Thibault Denamiel, Matthew Schleich, and CSIS. 2024. “Optimizing U.S. Export Controls for Critical and Emerging Technologies.” A Report of the CSIS Scholl Chair in International Business. https://csis-website-prod.s3.amazonaws.com/s3fs-public/2024

[xi] García-Herrero, Alicia. 2023. Resilience of Global Supply Chain: Facts and Implications. https://doi.org/10.56506/UKPK2510.

[xii] Public Law 117-167 (PL 117-167) for the CHIPS and Science Act

[xiii] Badlam, Justin, Stephen Clark, Suhrid Gajendragadkar, Adi Kumar, Sara Slayton O’Rourke, and Dale Swartz. 2022. “The CHIPS and Science Act: Here&Rsquo;S What&Rsquo;S in It.” McKinsey & Company. October 4, 2022. https://www.mckinsey.com/industries/public-sector/our-insights/the-chips-and-science-act-heres-whats-in-it.

[xiv] Reinsch, William, Thibault Denamiel, Matthew Schleich, and CSIS. 2024. “Optimizing U.S. Export Controls for Critical and Emerging Technologies.” A Report of the CSIS Scholl Chair in International Business. https://csis-website-prod.s3.amazonaws.com/s3fs-public/2024

02/240214_Reinsch_Export_Controls.pdf?VersionId=7szUlbDuJHyE7fKuiMtB_dlad_aHmOlN.

[xv] Regulation (EU) 2023/1781 of the European Parliament and of the Council of 13 September 2023 establishing a framework of measures for strengthening Europe’s semiconductor ecosystem and amending Regulation (EU) 2021/694 (Chips Act), OJ L 229, 18.9.2023, p. 1.

[xvi] European Commission “European Chips Act.” 2023. European Commission. https://commission.europa.eu/strategy-and-policy/priorities-2019-2024/europe-fit-digital-age/european-chips-act_en.

[xvii] Center for Strategic and International Studies. "The World Chips Acts: The Future of US-EU Semiconductor Collaboration."https://www.csis.org/analysis/world-chips-acts-future-us-eu-semiconductor-collaboration.

[xviii] Reinsch, William, Thibault Denamiel, Matthew Schleich, and CSIS. 2024. “Optimizing U.S. Export Controls for Critical and Emerging Technologies.” A Report of the CSIS Scholl Chair in International Business. https://csis-website-prod.s3.amazonaws.com/s3fs-public/2024

02/240214_Reinsch_Export_Controls.pdf?VersionId=7szUlbDuJHyE7fKuiMtB_dlad_aHmOlN.

[xix] Ravi, Sarah. 2022. “The Growing Challenge of Semiconductor Design Leadership - Semiconductor Industry Association.” Semiconductor Industry Association. November 30, 2022. https://www.semiconductors.org/the-growing-challenge-of-semiconductor-design-leadership/.

[xx]   Tomoshige,Hideki and  Crane, Bailey“RAI Explainer: Strategic Importance of Continued U.S. Leadership in Chip Design | CSIS.” n.d. https://www.csis.org/blogs/perspectives-innovation/rai-explainer-strategic-importance-continued-us-leadership-chip.

[xxi] Congressional Research Service. “Semiconductors: U.S. Industry, Global Competition, and Federal Policy.” Report No. R47508, May 2, 2023. https://crsreports.congress.gov/product/pdf/r/r47508.

[xxii] Reinsch, William, Thibault Denamiel, Matthew Schleich, and CSIS. 2024. “Optimizing U.S. Export Controls for Critical and Emerging Technologies.” A Report of the CSIS Scholl Chair in International Business. https://csis-website-prod.s3.amazonaws.com/s3fs-public/2024

02/240214_Reinsch_Export_Controls.pdf?VersionId=7szUlbDuJHyE7fKuiMtB_dlad_aHmOlN.

^[xxii] European Commission “European Chips Act.” 2023. European

[xxiii] Handelsblatt “Die Deutschen spielen eine entscheidende Rolle im globalen Chipgeschäft” May 19, 2023. https://www.handelsblatt.com/technik/it-internet/halbleiter-die-deutschen-spielen-eine-entscheidende-rolle-im-globalen-chipgeschaeft/24360844.html.

[xxiv] Ibid.

[xxv] Reuters "U.S. Pushing Netherlands, Japan to Restrict More Chipmaking Equipment to China: Source." Reuters, June 18, 2024. https://www.reuters.com/world/us-pushing-netherlands-japan-restrict-more-chipmaking-equipment-china-source-2024-06-18/.

[xxvi] Ibid.

[xxvii] Colby, Marc, and Patrick Tay. "Collateral Damage: The Domestic Impact of U.S. Semiconductor Export Controls." Center for Strategic and International Studies, August 21, 2023. https://www.csis.org/analysis/collateral-damage-domestic-impact-us-semiconductor-export-controls.

[xxviii] Reuters Dutch Trade Minister: Won't Summarily Agree to U.S. Rules on China Exports." Reuters, January 16, 2023. https://www.reuters.com/technology/dutch-trade-minister-wont-summarily-agree-us-rules-china-exports-2023-01-16/.

[xxix] Colby, Marc, and Patrick Tay. "Collateral Damage: The Domestic Impact of U.S. Semiconductor Export Controls." Center for Strategic and International Studies, August 21, 2023. https://www.csis.org/analysis/collateral-damage-domestic-impact-us-semiconductor-export-controls.

[xxx] Ibid.

[xxxi] Ibid.

[xxxii] Hart, N. M., and C. A. Casey. ”Transatlantic Leadership in an Era of Human Rights-Based Export Controls.” Journal of International Economic Law 27, no. 1 (2024): 130–46. https://doi.org/10.1093/jiel/jgae005.

[xxxiii] Ibid.

[xxxiv] Wolf, K., ‘Testimony before the Senate Committee on Banking, Housing and Urban Affairs “Advancing National Security and Foreign Policy Through Sanctions, Export Controls, and Other Economic Tools”’ 2023

[xxxv] European Commission. "EU Enables Coordinated Export Controls by Compiling National Lists." European Commission Policy. October 26, 2023. Accessed August 26, 2024. https://policy.trade.ec.europa.eu/news/eu-enables-coordinated-export-controls-compiling-national-lists-2023-10-26_en.

[xxxvi] Ibid.

[xxxvii] European Commission. Export Controls: Protecting Critical Technologies. Last modified April 25, 2023. Accessed August 26, 2024. https://circabc.europa.eu/ui/group/aac710a0-4eb3-493e-a12a-e988b442a72a/library/a44df99c-18d2-49df-950d-4d48f08ea76f/details?download=true.

[xxxviii] European Parliament. "Outbound Investment Screening." Last modified October 2023. Accessed October 2, 2024. https://www.europarl.europa.eu/legislative-train/carriage/outbound-investment-screening/report?sid=8401.

[xxxix] European Parliamentary Research Service. The Future of the EU Semiconductor Industry: Challenges and Opportunities.2023. https://www.europarl.europa.eu/RegData/etudes/ATAG/2023/751470/EPRS_ATA(2023)751470_EN.pdf.

[xl] European Parliament. Regulation on Export Controls of Dual-Use Items: Overview and Analysis. EPRS (European Parliamentary Research Service), August 2023. https://www.europarl.europa.eu/RegData/etudes/ATAG/2023/751470/EPRS_ATA(2023)751470_EN.pdf.

[xli] CSIS. 2023. “Developing an Economic Security Strategy: EU and US Approaches.” Center for Strategic and International Studies (CSIS). April 26, 2023. https://www.csis.org/blogs/geoeconomics-360/developing-economic-security-strategy-eu-and-us-approaches.

[xlii] European Commission. 2024. White Paper on Outbound Investments. European Commission. January 17, 2024. https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52024DC0024.

[xliii] U.S. Department of State. What is Civil-Military Fusion? Accessed August 26, 2024. https://www.state.gov/wp-content/uploads/2020/05/What-is-MCF-One-Pager.pdf.

[xliv] Rasser, Martijn, Emily Benson, and Hiddo Houben. Transatlantic Approaches to Outbound Investment Screening. Washington, DC: Center for Strategic and International Studies, 2023. https://www.csis.org/analysis/transatlantic-approaches-outbound-investment-screening

[xlv] Ibid.

[xlvi] Rasser, Martijn, Emily Benson, and Hiddo Houben. Transatlantic Approaches to Outbound Investment Screening. Washington, DC: Center for Strategic and International Studies, 2023. https://www.csis.org/analysis/transatlantic-approaches-outbound-investment-screening.