There are no more gray areas in AI cross-border mergers and acquisitions. The National Development and Reform Commission prohibits foreign investment from acquiring Manus and requires the cancellation of the transaction. Many people say that it's possible that the shareholders have already distributed the money after the delivery has been completed, why half? What else can be done to restore to the state before the transaction or even earlier. According to Article 12 of the Measures for the Safety Review of Foreign Investment, after the state makes a decision to prohibit investment, the parties concerned shall not implement investment; For those that have already been implemented, the equity or assets should be disposed of within a specified period of time and other necessary measures should be taken to restore them to their pre investment state. This is the core legal basis, emphasizing "restoring the original state within a time limit+eliminating the impact on national security". The law specifies which specific steps are required, but "disposing of equity or assets+other necessary measures" is a fallback requirement aimed at achieving comprehensive restoration from equity to data. In the hypothetical scenario where Meta's acquisition of Manus has been completed and the transaction has been revoked by regulatory requirements, the actual execution needs to cover multiple dimensions such as equity, assets, data, technology, business, and personnel, forming a systematic "recovery chain". The full chain restoration system of "equity → assets → data → technology → business → personnel → supervision". Let's talk about the arrangements for equity, acquisition funds, data, and other aspects that everyone is most concerned about after being asked to cancel the transaction: 1. Equity disposal (core starting point, must be completed within the deadline) All parties shall sign a written termination agreement, revoke the acquisition, and terminate all supporting documents (shareholder agreement, technology transfer agreement, etc.). If Meta has completed the equity delivery, it needs to transfer all the Manus equity held back to the original shareholders/domestic entities and complete the registration of changes in industry and commerce and overseas entities. The regulatory authorities will supervise equity changes to ensure that there is no "disguised control" (such as agreement control, proxy holding, etc.). 2. Return of funds and divestment of assets Meta needs to fully refund the $100 million (including deposits, prepayments, etc.) already paid for the acquisition to the relevant transaction account. After receiving the funds, the original shareholders need to complete the original foreign exchange refund and report to the foreign exchange regulatory department in accordance with regulatory requirements. Both parties shall handle intermediary fees, liquidated damages, etc., and it is prohibited to indirectly complete the payment of consideration through the names of "compensation" and "consulting fees". The foreign exchange management department conducts full verification of the funding path to prevent capital flight under the pretext of "terminating transactions" Dispose of or return the physical assets (servers, equipment, office space, etc.) and intangible assets obtained from the acquisition. AI companies typically involve a large amount of hardware/software assets that need to be inventoried, transferred, or destroyed to ensure that the Manus asset structure is restored to its pre Meta acquisition state. 3. Data security recovery (particularly critical in AI transactions, the core of eliminating national security impacts) 1) Comprehensively clean up, delete or return sensitive data obtained/accessed by Meta through acquisition (including training datasets, user/business data within China, algorithm input data, derivative data, etc.). 2) Cut off all data access permissions (API, cloud storage, backup, etc.), implement data isolation or destruction. 3) Ensure that data is not exported, used for training or commercial purposes by Meta, and complies with the requirements of the Data Security Law, the Personal Information Protection Law, and the Important Data Catalog. 4) If it involves cross-border data transmission, reverse processing of data export security assessment needs to be completed. 
 Other aspects include intellectual property and technology transfer, separation of business and operation, cleaning of contracts and legal documents, and of course, deep regulatory intervention. AI cross-border mergers and acquisitions no longer have gray areas The decision to ban investment this time is not targeted at a single case, but rather sets a clear boundary for the AI industry: it explicitly prohibits the transfer path of "domestic research and development+overseas shell replacement+foreign investment acquisition"; Cross border mergers and acquisitions in the AI field must undergo complete security review and data evaluation procedures; The control of AI technology developed within China shall not be transferred overseas without review.