
Earlier this year, the European Commission published a white paper and accompanying consultation on "outbound investments" as part of the European Economic Security Strategy. In it, the EC mentioned that investments in third countries in a number of critical technologies could risk EU know-how being used to undermine international peace and security. These are mainly technologies suitable for enhancing military and intelligence capabilities.
The white paper proposes an in-depth analysis of outbound investments from the EU, focusing on a limited number of key technologies, to determine the nature and extent of the associated risks and the need for policy responses.
The Commission proposes a step-by-step approach:
Monitoring:
First, it is proposed to monitor certain past and current outbound investments. This monitoring phase should last 12 months.
Risk Assessment:
It is then suggested that an assessment of the risks associated with such transactions be carried out based on the results of the monitoring.
Measures:
Finally, determine whether it is necessary to establish policies regarding certain transactions.
Although the consultation now mainly asks about the scope of the monitoring, we do think it is important to be involved in this dossier in a timely manner. We see international security as an important good. However, the monitoring and any measures that might be proposed at any time must be appropriate. In our response we address, among other things, the type of transaction, the technologies involved and the size of the transactions in the scope of the monitoring. For example, we emphasize the importance of clear definitions of portfolio investments, among other things, we propose a threshold for the size of transactions in scope and call attention to ESG/impact investments.