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European climate on foreign investment
- 2. © Brunswick 2017 | 2
Whathashappened?
In a policypaperon tackling
globalisationpresentedon 10 May,
the EuropeanCommissionraises
concernsaboutforeign investors,
notablystate-ownedenterprises,
takingover “Europeancompanies
with keytechnologies forstrategic
reasons”. Italsoregrets the lackof
reciprocityfor investmentconditions
in some countries.While no mention
is made of China, thisis a clearnod to
severalrecent callsfrom politicians
acrossthe Union for a united front in
dealingswith Chineseinvestment.
In February2017,the governmentsof
France,Germany and Italysent a letter
to the EuropeanCommission,calling
on it to rethink ruleson foreign
investmentinto the EU and to allow
Member Statesto block outright a
specificforeign investmentor make it
subjectto conditions.In March, the
EuropeanParliamentcalled forthe
creationof a European-level
committeeto review “sensitive”
foreign investments,with a particular
focuson China.Theseactionscome at
a time when Chineseinvestmentin
Europeincreasedsignificantlyin 2016,
and the effectsof globalisationand
free tradeare being questionedby
populistsin many countries.
While the Commission’s10 Maypaper
includesno concretelegislative
proposal,it hasbeen interpretedasa
request to Member Statesfor a
politicalmandateto addressthisissue.
The Commissionisexpectedto give a
strongerindicationof itsintentionsin
the President’State of the Union
speechin September, whichmay
includea commonapproachto
regulatesuchinvestments.
EuropeanContext
The backdropto thispolitical
rumbling is the rapidincreaseof
ChineseDirectInvestmentinto
Europeoverthe lastfew years. The
China Manufacturing2025strategy,
whichaimsto drive an upgradein
China’smanufacturingand industrial
sectorand to assertitsleadership in
high-valueand highlyinnovative
segments of the global economy,has
drawn many to see politicalmotives
alongsideinvestment considerations.
A key componentof thisplanis to
achievedomestic contentof core
components andmaterialsof 40%by
2020and 70%by 2025across tenkey
sectors,or so-called‘indigenous
production’.
Thisstrategy,together withother
economicdrivers,hasled to a wave of
deal making by Chinesecompaniesin
Europeand beyond,focusingon
acquiringknow-howand technology
in highlystrategicsectorssuchasnew
energy vehicles,industrialrobotics
and semiconductors.
The EU is an importantdestinationfor
Chineseinvestors,with more than €35
billionof completed transactionsin
2016, anincreaseof 77 per cent from
2015. Chineseinvestmentin Germany
rosefrom €1.1billionin 2015to
almost€11billionin 2016. It should
be noted thatthiscomesafter
substantiveinvestmentfrom EU
Member StatesacrossChina over the
previous 20-30years.
As an increasing
number of voices
from the politicaland
the business world
are asking Europe to
take a more hawkish
approach to foreign
investments
targeting European
know-how and
strategic industries
(along the linesof
CFIUS, the Committee
on Foreign
Investment in the
United States), recent
politicalactivities
certainly indicate
substantive policy
change in thisfield
can be anticipated at
some stage. It
remains to be seen
whetheraction will
be taken at pan-
European levelor
unilaterallyby some
countries.
- 3. © Brunswick 2017 | 3
Brunswick Group
European climate for foreign investment
While China’s efforts to upgrade its
industrial base are welcomed by
European businesses and
politicians, some are wary of the
perceived interventionist role
played by the Chinese government
inthis strategy, which they say is
driven by the government’s
agenda rather than pure market
forces.
This perception of Beijing’s close
involvement in outbound
investments has stoked twofold
fears inEuropean countries: that
their own national security could
be compromised; and that the
Chinese Government’s directives
together with financial aid, tilt the
playing field infavour of Chinese
companies. Some politicians argue
Beijing ismaking use of tools such
as subsidies, continued support for
state-owned enterprises, and
state-backing for acquisitions of
foreign companies on one hand
while limiting market access for
foreign business.
Indeed, while private companies
are perceived to be working
closely with the State on the goals
of China Manufacturing 2025,
investment by European
companies inChina continues to
face many barriers, such as joint
venture requirements resulting in
a comprehensive transfer of
technology incertain industries for
example, all of which contributed
to European investment inChina
falling this year to a 10-year low.
These concerns peaked in
Germany with the acquisition of
robot maker Kuka by Chinese
appliance maker Midea, and are
now widely shared by other large
Member States such as France and
Italy.
Investment flowsbetween
China and Europe
Source: Rhodium Group/MERICS
Source: Rhodium Group/MERICS/Politico
Chinese FDIin Europesurges, whileEU FDI in China declines
Value of FDI transactions between EU-28 and China, EUR million
- 4. Brunswick Group
EU-China Trade Relations
© Brunswick 2017 | 4
STX France shipyards: How the French
government dissuaded Hong Kong’s Genting
from bidding
Inthesecond half of 2016, thesale process of theSTX France shipyard
revealed theFrench State’s interventionist practices when it comes to M&Ain
strategic sectors. The shipyards are considered anational “industrial gem” and
are representative of aEuropean expertise thattheFrench government is
unwilling to see transferred to another country, and even less to China. The
French stateholds a33 percent stakein STX France.
Thesale of STX France formed part of thebroader sale of thecollapsed South
Korean STX shipbuilding group led by theSeoul Central District Court at the
end of 2016. Seoul’s Commercial Court identified four interested parties in
November 2016, including Italy’s Fincantieri SpAand theNetherlands’ Damen
Shipyards. TheHong Kong-based group Genting HK, Malaysian in origin but
seen as a“Chinese” company in France, hadto renounce theirformal bid even
before it was filed after facing opposition from public officials and
representatives of thec.7,000 employees.
Whereas two of thebidders quickly dropped outof thecompetition, Genting
HK was “very enthusiastic about Saint-Nazaire after having taken over four
shipyards in Germany in 2016”, according to France’s most influential daily
newspaper Le Monde. Thesame article, however, quotedthree sources
reporting that“French public authorities managed to dissuade them”. Another
source even added that“two or three weeks were enough to explain to
Genting’s leaders how unpopular their intervention was, and to detail the
measures theStatewould implement if theywere to proceed [withtheir
intention to bid]”.
Interestingly, theultimatesuccessof theItalian group Fincantieri did not put
an end to theSTX saga. Indeed, Fincantieri iscurrently in a joint venture with
thestate-owned ChinaStateShipbuilding Corp., raising concerns of potential
technology transfers to China. TheFrench Stateintervened to prevent
Fincantieri from holding amajority stake, and brought in another French
group, DCNS, into theshipyard’s capital to secure “French interests”.
“Currently,the governmenthasthecapacityto oppose
an acquisitionthatwe believeisbad for the economic
and socialstabilityof thecompany”
MichelSapin (Ministerof Economy)
Ina number of Member States,we see
anti-Chinese rhetoric being taken up by
companies involved in deals in an effort
to gain political support for their bid.
This wasthecase recently in France for
example, where one of thecompanies
bidding for theacquisition of theSTX
France’s shipyards was successfully
sidelined by theother contenders
because of itsproximity to China.
Similar rhetoric isnow being usedby
theFrench government to dilute the
stake of thefinal bidder, Italian
company Ficantieri, who hasvery close
links and a technology transfer
agreement with ChinaState
Shipbuilding Corp., a Chinesestate-
owned enterprise.
What are the
implications?
Companieswishingto investin Europe
need to ensure their strategicand
financialrationaleforany proposed
acquisitionis well understoodby
politicaland businessstakeholdersin
Europe, soasto counterany concerns
it may be partof an orchestrated
campaign/”sponsored”by the Chinese
Government.
Theymust also invest in
communicatingthe company’s
mission,itsorigins,itsvalues and its
business model.Chinesecompaniesin
Europeoften sufferfrom an
understandingdeficitfrom the
Europeanpublicand politicalworld,
whichcan contributeto negative
perceptions of aspecificdeal.
- 5. © Brunswick 2017 | 5
European responses to
Chinese investment to
date
Currently, EUlegislationallows
Member Statesto prohibitforeign
investmentswhichthreatenpublic
security and publicorder,but it does
not let them takeinto account
economiccriteria orthe reciprocity of
the investment conditions.A number
of Member Statesalsohavespecific
legislationin placeallowingthem to
review foreign investmentsbut the
use of thesedefence mechanismsis
lessfrequent than in the caseof the US,
China and Australia.Francehasa long
historyof vetting and potentially
blockingforeign acquisitions under
certainconditions,but mostother
Europeancountrieslimit themselves
to reviewing investmentswhichare
linkedto nationalsecurity,suchas
defence industryenterprisesor
companiesthatare involvedin IT
security and theprocessingof state-
classifieddocuments,asis the casein
Germany,for example.
The German government hasbeen
spearheadinga movement in Brussels
to broaden EU rulesto allowMember
Statesto protectcompaniesworking
in strategicsectorsfrom approaches
driven by industrialpolicyor aiming
for technologytransfers. While
Germany hasconsidered
implementing stricterrulesbilaterally,
itsgovernment hasconcludedthat
onlyan EU-wideapproach wouldbe
efficient.In February2017,it received
the supportof the Frenchand Italian
governments,who co-signedthe
aforementionedletter to the European
Commissionerfor Tradeaskingit to
createthe legal basisfor national
governments to be able to “intervene
in directinvestmentswhichare state-
controlled”.
At the sametime, Germany is
preparinga new strategyfor itstrade
relationswith China,whichsuggests
thatthere are two conversations
takingplacewithin the Government–
one protectionist;and one supportive
of increasedtrade.
In response, theEuropean
Commissionissaidto be preparinga
proposal toallowMember Statesto
blockan acquisitionthatis“politically
motivated”.In particular,it would
focuson the followingsectors:
airports,ports,railway infrastructure
and relatedsuppliersaswell as high
technology,investmentsin raw
materials,strategicprojectssuchas
the Europeansatelliteprogram
"Galileo"or companies activein the
nuclearindustry. Thisproposalmay
be announcedby the Commission
Presidentin September.
For itspart,the EuropeanParliament
hasalso been watchingclosely
developmentsrelating to Chinese
investmentin Europe.The recent
proposal bya groupof EPPMEPsfor a
new Union actallowingEU
interventionin the caseof foreign
investmentthat“doesnot complywith
market rulesor isfacilitatedby state
subsidiesresultingin a likelymarket
disturbance”or in the absenceof
reciprocityfor Europeaninvestment in
the thirdcountryis the latestresponse
to the situation.Notethatasthe
EuropeanParliamentdoesnot havea
right of initiative,any proposalwould
need to be made by the European
Commissionto be considered for
implementation.
EU Legislative
Process
Thelegislative process of the
European Union israther complex.
TheEuropean Commission is the
executive body responsible for
proposing legislation, which must
thenbe adopted in a co-decision
process by theEuropean Council
(therepresentatives of theMember
States) and theEuropean
Parliament (with directly elected
members). Any EU-wide
legislation on thismatter would
need unanimous support from all
Member Stateswhich would be
incredibly difficult to achieve given
thediverging interests.
Indeed, Member Statescurrently
havelittle appetite to give more
powers to theEuropean
Commission. They are also
competing among each other for
attracting new foreign investment,
making it unlikely thattheadopted
legislation will be very robust –if
any agreement will be
reached at all.
Thepaper released on 10 Mayis an
invitation by theEuropean
Commission for Member Statesto
give it astrong political mandate
on thismatter, but also to consider
other possible actions instead of
protectionist measures.
© Brunswick 2017 | 6
- 6. Brunswick Group
EU-China Trade Relations
© Brunswick 2017 | 6
Midea-Kuka:How the Chinese takeoverof a
German “pearl” transitionedfrom a threat to a
blueprint for future Chinese-German deals
Midea is aprivate, listed, Chinese white-goods company with astrong
international footprint and previous outbound deal experience. Kuka is a robot
manufacturer occasionally called a “pearl” of German industry. Apartnership
looked promising, with mutualbenefits for both companies. InMay 2016,
Midea formally announced its intention to increase its13.5% stake in Kuka to
above 30%.
One week after theannouncement, Kuka hostedtheir annual general
shareholder meeting, during which various shareholder representatives
expressed their concerns about thesale of German technological know-how
and potential job losses. Withindays of theshareholder meeting, EUand
German politicians publicly commented in opposition toMidea’s offer. EU
Digital Commissioner GüntherOettinger commented: “Kuka is asuccessful
company in astrategic sector with important significance for thedigital future
of European industry. Since there wasno call for help to China,we shouldbe
allowed to consider whethera European approach could be abetter solution
for Kuka.” Blocking actions suchasan investment cap of 49% were also
considered.
Some in thepolitical community in Germany, led by thenEconomics Minister
Sigmar Gabriel, wanted to examine thedeal under Germany’s Foreign Trade
Law. Upon review, thegovernment determined thattheLaw’s scope did not
cover companies suchas Kuka, whichis not considered part of acritical
industry. Political risks thenescalated asAngela Merkel flew to China for an
official visit; thedeal ran therisk of becoming a symbol for imbalanced trade
and investment between Chinaand Germany.
However, fears were allayed once Midea and Kuka formalized their
partnership in an Investment Agreement, in which conditions alleviated
concerns by securing jobs and sitesthrough 2023 – farbeyond theindustry
standard. With thesuccessfulend of thetender offer period, after whichMidea
gained 95% of Kuka’s shares, themedia regularly named Midea‘s investment
in Kuka as arole model for otherongoing Chinese-Germany takeover offers. By
December 29, 2016 theMidea-Kuka deal had passed all antitrust and foreign
investment clearance globally.
“TheKuka modelsuggests thatcash alone won’t be enough.
Mideapledgedto keep jobs, managementand customer
datain Germanyforseven and a halfyears,faroutstripping
typicallocalstandards.ThatallayedGermanfearsof
technology theftand reassuredclients such as Daimlerthat
blueprintswere in safehands.”
ReutersBreakingviews(11 October2016)
Broader political
considerations
Generallyspeaking, theEU and
Member StateslikeGermany tend to
be in favourof free trade.The backlash
againststate-drivenforeign
investmentsis specificallydirectedat
China,and is balanced bya strong
belief thatforeign directinvestmentis
positivefor a country. TheEuropean
Commissionin particularis strongly
committedto free trade,and relieson
it as a politicaltool to bring its trading
partnerscloserto its own model.The
Commissionconsidersreciprocityas
crucialfor any free tradepolicy,
howeveris also adamantthatthis
shouldaim for China to become as
open as Europe,rather thanEurope
closingitselfto imitateChina.It
nonethelessacceptscertainsecurity
concernsand is closelymonitoring the
recent Chineseacquisitions.
- 7. © Brunswick 2017 | 7
Brunswick Group
European climate for foreign investment
In a contextwhere any new legislation
wouldrequire unanimous agreement
by all Member States,diverging
interestswithin the EU will matter
enormously.
Central and EasternEuropean
countriesin particularhavewarmly
welcomedChineseinvestmentasa
sourceof cashfor their economies,and
resent German effortsto curtailsuch
investment.They are emerging asone
of the top destinations forChinese
capital,stronglysupportedby political
initiativeslikethe 16+1and the China-
Central and EasternEurope
CooperationFund.Theirneed for FDI
and weak marketpositionmake them
an idealplatformfor China to leverage
itsgrowing influencein the EU as a
whole.Thisenhancedcooperationhas
alreadysparked tensionswith both
bigger Member Statesand Brussels.
Some Europeanbusinesses,including
German companies,are alsosceptical
of their governments’attemptsto slow
Chineseinvestment.For them, such
investmentprovideswelcomecapital
in the shortterm whilealsohelping
with marketaccessin the longer term:
havinga large Chineseshareholderis
often a helpfuldooropener in China.
Diverging interestsare alsoapparent
withinindividualMember States,with
some governmentsleading the charge
againstChina in Brusselscontinuingto
promoteincreasedChinese
investmentin their countries.French
Prime MinisterBernardCazeneuve
didso in an outspokenmanner during
a recent visitto Beijing,justashis
government signedthe letter to the
EuropeanCommission.The two
conversations takingplacein Germany
are alsoclearly apparentin France.
At the sametime, considerations on
the role of the Chinesegovernment in
tradeand investment are alsoat play
in the debate on China’sWTO status.
Itsstatusasa “non-marketeconomy”
(NME),under whichit joinedWTO in
2001, expiredat the end of 2016,
causingBeijingto ask to be recognised
asa marketeconomyby itstrading
partners. TheEU and the US havebeen
reluctantto grant it thisstatusasit
wouldmake imposingantidumping
and countervailingdutieson Chinese
importsmore difficultfor them.
China isnot a free market by any
standards,but it isentitled by WTO
rulesto accessmarket economystatus.
Thishasled the EU to considerother
means to addresstradedistortions.
While thisisa separatedebate from
thatof investmentin strategicsectors,
it certainly constitutesa backdropto
Europeanconcernsof Chinesestate
interventionismin all aspectsof its
industrialpolicy.
Competing Member States
with diverging interests
Source: Rhodium Group/MERICS
- 8. © Brunswick 2017 | 8
The viewfrom the U.S.
CFIUS- The Committeeon Foreign
Investmentin the United States
(CFIUS)hasthe authorityto review,
for nationalsecurityreasons,any
transactionthatwouldresultin a
foreign entity havingcontrolof a U.S.
asset.Historically,the U.S. has
supportedan ‘open investment’
approach and CFIUShasnot taken into
accounttradeconsiderationsor
questions of reciprocity.In a recent
interviewwith Bloomberg,Treasury
SecretarySteve Mnuchin,saidthat
CFIUSwouldcontinueto focuson
nationalsecurity issues.
America First?- However in the same
interviewhe alsoacceptedthatin
“certainthings”the Committee’sremit
could beexpandedand, it iscertainly
true,thatthe conditionsfor CFIUS
reform havenever been greater. An
increasein Chineseinvestmentsinto
the U.S. since2012and the
convergenceof anti-ChinaRepublicans
and anti-tradeDemocrats inCongress
mean the open investmentapproach is
being questioned bysome.
The Hillis on the move - Senate
MajorityWhip John Cornyn and
Senate MinorityLeaderCharles
Schumerare expectedto introduce
separatebillssoonaimed at reforming
the Committee.Senator Cornyn’sbill is
expectedto single outinvestmentsin
particularsectors,suchas
semiconductors,and investments
from particularcountries whichmay
require closervetting,while Senator
Schumer’sbill is expectedto addan
economic“net benefit” test to CFIUS
review criteria.The onlyquestionis
whether any legislativeeffortcoming
outof Congresswill havethe support
of the White House.
Pressureon the Administration-
There havebeen some noisesfrom the
AdministrationthatCFIUScould be
usedasa toolfor dealingwith China,
but anyattemptat reforming CFIUS–
especiallyto includeeconomic
considerations– isunlikelyto be
politicallyacceptablegiven the knock
on effectsto jobsand investment that
wouldresultfrom reducingforeign
capital.However,sectorswhichare
particularlysensitiveincludetelecoms,
artificialintelligence,robotics,
semiconductorsand satellites,and
transactions,whichmay require
significantmitigationmeasuresto get
them approved, facea more difficult
time.
The viewfrom China
Chinagoing global – Chinese
business willcontinueto seek
expansionoverseasdriven by a
coolingdomesticeconomy.However,
tightening capitalcontrolsand greater
scrutinyof investmentoutside
investors’core businesswill impact
the paceof investmentin the near
term.
Belt-Roadand “16+1”– The Belt and
RoadInitiative,whichaimsto connect
China with Europe,the MiddleEast
and Africaalongthe ancientSilk Road
landand sea routes, willdrive
significantinvestmentinto these
countriesstrategicallyprioritizedby
the Chinesegovernment. State owned
enterprisesmay end up leadingthe
charge,with privatebusinessesdriven
by theirown businessrationale. A
similar situationwill applyto the
“16+1”initiative,whichisChina’s
strategyto engage with Central and
EasternEurope.Investment across
both initiatives isfocusedon
infrastructure.
Investingin Europe – Europewill
remain a topdestination.Chinese
investorsare confidentthatthere is
growth in the Europeanmarket.
Overall,assetvaluationsare attractive
in Europeand there are many
technologicallyattractivecompanies
thatmatchChinesecompanies’needs.
A challengingyear ahead – 2017will
be challengingfor ChineseM&A,asthe
Chinesegovernment imposesstrict
controlon the use of foreign
exchangesto containthe outflowof
capital.In addition,the European
politicalclimateremains uncertain
with electionsin key EU member
states and Brexit negotiations. Inthe
pastmany Chineseinvestorsselected
the UK asa gatewayto Europe. This
strategyisnow uncertain.
Manage challenges– For all the
concernsaboutChineseinvestmentin
Europe, itremainsearlydaysin
China’s“go global”journey.The
volumeof successfulinvestmentsis
increasing,but it will be an on-going
learning process forChinese
companiesto understandthe
investmentand regulatory situationin
Europeand navigatelocal
stakeholders and issues.
- 9. © Brunswick 2017 | 9
Looking Ahead
With elections underwayin France,
the UK and Germany it is unlikelythat
the EuropeanCommissionwill get the
politicalimpetusit ishopingfor to
swing into legislativeactionthisyear.
Althoughthe Frenchand German
governments havesignalleda will to
cooperate more closelyon a
Europeanlevel on thisissue,their new
governments will haveother priorities
at the beginning of their term. At the
same time, the UK’s withdrawalfrom
the EU maygive the Franco-German
regulatoryapproacha bigger chance
to prevail,whichcouldleadto new
Europeanregulationon foreign
investmentsduring thisEuropean
Commission’sterm (whichends mid-
2019).
Furtherafield,DonaldTrump’s
electionisalsostartingto impact
China’sapproach to Europe.American
protectionismmakesEuropean even
more importanttradingpartner for
China,whichit cannotaffordto lose.
PresidentXi Jinping’s call inDavos
earlierthisyearin favourof free trade
was– cautiously –welcomedin
Brussels,but all stakeholders arenow
waitingto see whether thiswill be
followed byconcreteactionsto open
up China.In February, theChinese
government releasedplansto relax
restrictions onforeign investment and
make it easierfor overseascompanies
to liston domesticmarkets,which
were again welcomedby Europeans.
However,yearsof unfulfilled promises
by the ChineseGovernment on
economicreformshaveweakened
Europeanconfidencein the abilityof
Beijing to trulydeliver.The shifting
global politicallandscape,slowing
growth in Chinaand increasing
pressurefrom Europeangovernments
may raisethe stakesfor Beijing to
open up and preservegoodwill among
itskey partners.
What does this mean
for companies wanting
to invest?
It remains to be seen whether thisis
the latestsignal of a growing
protectionistbacklash against foreign
investmentin Europe’smostsensitive
industries ormerely the development
of a more strategicapproachto
protectingspecificsectors.Recent
politicalactivitiescertainly indicate
substantivepolicychangein thisfield
is to be anticipated,althoughany
politicalactionwill taketime and unity
among EuropeanMember States.
ConcernsaroundChineseinvestments
are unlikelyto decreasehowever,and
may leadto unilateralactionby some
countries.
At the sametime, the lack of pan-
Europeanactionleadsto the
continuationof fragmented national
policies.Thismeans foreign investors
in Europefacea variety of legislative
frameworks and diversepolitical
contexts,whichmight make the
investmentlandscapemore difficult.
EU actionwouldcreatea ‘one-stop-
shop’and provideinvestorswith more
clarityand more transparencyasto
how their investments willbe judged.
In times of politicaland regulatory
shiftssuch asthese,whichcan be
decisivein drivingmarketoutcomes
and determining business
environments,the need for clear,
concisecommunicationsbetween
companiesand their political
stakeholders isever important.
For Chinesecompanies lookingto
acquirecompaniesin Europe,as much
asfor Europeancompanieswelcoming
foreign directinvestment,well-
plannedstakeholderengagement and
communicationscan improvetrust
and havea genuine impact onthe
potential forthe transactionto
succeed:
̶ Understand the context: identifying and
understanding the issues that will
impact the transaction in the local
market and more broadly across
Europe is key to anticipate and
addressing concerns early in the
process. Political considerations can
impact a deal as much as financial ones.
̶ Develop a narrative to address these
issues: presenting a clear story onthe
value of the investment proposed, going
beyond the pure financial rationale to
explain the benefits to the local
economy and society will help mitigate
concerns and build political goodwill for
the proposed transaction.
̶ Engage the right stakeholders: staying
quiet will not keep the deal away from
political attention. Building support
among relevant stakeholders who can
influence perceptions of the company
and the proposed transaction will be
decisive. Engagement should be
sustained throughout the transaction
and be adapted toany political
developments.
Companies thinkingaboutinvesting
in the U.S. should try to situatetheir
investmentsin the President’s
“AmericaFirst”philosophy. Theyneed
to be clearaboutthe rationalefor their
transactionand set the right tone from
the startby, for example,being able to
make a strong,credibleargument
aboutthe positiveimpact onU.S.jobs.
Thiscan help to manage the external
noisethatoften existsaroundCFIUS
reviewedtransactionsin the media,on
the Hill and among investors.They
shouldalsostartto establishearly
relationshipswith the Administration
– after all,familiaritybreeds trust– by
engaging earlyand planning well in
advance.
- 10. Brunswick Group
European climate for foreign investment
© Brunswick 2017 | 10
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