Case Studies

How companies use TBRAC to identify risk early, remediate strategically, and enter the US market with confidence.

AI / National SecurityShenzhen, China

Major AI Systems Provider

Very HighMedium

A leading Chinese AI company developed advanced facial recognition technology and sought a contract to deploy it across US airport security checkpoints. Given their sector and government adjacency, their initial TBRAC screening flagged immediate exposure across multiple dimensions.

Key Findings

  • Mandatory CFIUS filing required — transaction met TID US Business threshold under FIRRMA
  • Company name appeared on DoD 1260H list of Chinese military-civil fusion entities
  • CCP party committee embedded at board level with no independent US governance structure

Outcome

TBRAC's early identification gave the company 8 months to restructure before filing. They established a US subsidiary with a fully independent board, removed party committee representation from governance documents, and engaged CFIUS counsel proactively. The transaction cleared review. Risk tier: Very High → Medium.

EV / ManufacturingJiangsu, China

Jiangsu Power Solutions Group

HighLow

A major EV battery manufacturer sought to become a Tier-1 supplier to a top-three US automaker. The deal involved significant IP transfer and a proposed joint venture. A 32% stake held by a provincial state-owned enterprise created material CFIUS exposure.

Key Findings

  • SOE ownership at 32% exceeded thresholds for critical technology supplier classification
  • US customer data — including vehicle telemetry — routed through servers in Nanjing with no data localization controls
  • Export Control Classification (ECCN 3E001) not assessed for battery chemistry formulations transferred to US JV

Outcome

The company reduced SOE stake to 8% through a secondary share offering, established a US-based data subsidiary with isolated infrastructure, and completed an ECCN classification analysis. CFIUS review completed without mitigation agreement. Certified Low risk in 14 weeks.

Enterprise SaaSBeijing, China

Beijing Workforce Technologies

MediumLow

A Beijing-based HR software company targeting Fortune 500 US clients had a relatively clean profile — fully private ownership, no government contracts, and strong IP documentation. TBRAC was used to identify the remaining gaps before a US sales launch.

Key Findings

  • No US employment law compliance framework for software handling US employee PII (CCPA, BIPA gaps)
  • Financial statements not prepared under US GAAP or audited by a PCAOB-registered firm
  • Vendor agreements with two entities on BIS Unverified List flagged in supply chain screen

Outcome

The company engaged a US employment counsel to implement a CCPA-compliant data handling framework, transitioned to a PCAOB-registered auditor, and replaced the flagged vendors. Entity list screening returned clean. Achieved Low risk certification in 6 weeks with no structural changes required.