China has now moved decisively to tighten state control over outbound investment. With the State Council’s Regulations on Outbound Investment set to take effect on July 1, 2026, China has created its clearest legal basis yet to review, restrict, unwind and penalize overseas transactions involving Chinese investors where national security, technology, data or other strategic interests are at stake.

Legal systems remain different, and they should remain different. But parties engaged in international commerce increasingly expect the same basic things: neutrality, efficiency, fairness, court support and enforceability. 

Convergence is therefore not the disappearance of legal diversity. No, it is the building of a shared procedural trust.