ABSTRACT
This chapter adopts a comparative perspective to evaluate the national security review regimes in the United States and China, the top two host countries for foreign investment in terms of monetary value. It considers the structural layouts of national security review regimes in these two countries, the economic backdrops, the political economies underlying institutional design, and their interplay with other regimes. It finds that while the US and Chinese national security review regimes bear a degree of formalistic resemblance due to China’s transplantation of some mechanisms from the United States, they have contrasting effects in implementation. The divergence derives from nuanced differences in the two regulatory frameworks and the distinctive political economies behind institutional designs.
