Chinese social network Weibo published its annual report last week. In it was a warning — the same one the company has published regularly since it first went public in New York in 2014 — that its corporate structure is a convoluted workaround to sidestep a Chinese curb on foreign investment in tech. It’s one of more than a hundred companies that can say the same. Grey areas feature prominently in the history of US-Chinese flows.
Sometimes, though, the grey turns suddenly to black and white. Meta Platforms, owner of Facebook, has been ordered by Chinese regulators to unwind its $2bn acquisition of Manus, a maker of AI software. Manus isn’t Chinese, but it used to be: it relocated to Singapore last year, before Meta snapped it up. Legal as that might have been, Beijing sees a “conspiratorial” attempt to spirit valuable technology abroad.
Practices such as “Singapore washing”, as relocating to the city-state for investment reasons is known, or the “variable interest entities” that enable foreign money to enter companies like Weibo in forbidden sectors, have brought capital to companies that might otherwise have struggled to get off the ground. While China has plenty of tech talent, it’s the US that has the cash. Private investment in AI companies in the US reached $286bn in 2025, according to Stanford University; China mustered just $12.4bn.